Change to read: quality standards for CSPs of drugs and nutrients
based on current scientific information and best sterile compounding practices. The use of technol- ogies, techniques, materials, and procedures other than those described in this chapter is not prohib- 797 PHARMACEUTICAL ited so long as they have been proven to be equiva- lent or superior with statistical significance to COMPOUNDING those described herein. The standards in this chap- STERILE PREPARATIONS ter do not pertain to the clinical administration of CSPs to patients via application, implantation, in- fusion, inhalation, injection, insertion, instillation, and irrigation, which are the routes of administra- INTRODUCTION tion. Four specific categories of CSPs are de- The objective of this chapter is to describe con- scribed in this chapter: low-risk level, medium-risk ditions and practices to prevent harm, including level, and high-risk level, and immediate use. Ster- death, to patients that could result from (1) micro- ile compounding differs from nonsterile com- bial contamination (nonsterility), (2) excessive pounding (see Pharmaceutical Compound- bacterial endotoxins, (3) variability in the intended ingNonsterile Preparations 795 and Good strength of correct ingredients that exceeds either Compounding Practices 1075) primarily by re- monograph limits for official articles (see offi- quiring the maintenance of sterility when com- cial and article in the General Notices and Re- pounding exclusively with sterile ingredients and quirements) or 10% for nonofficial articles, (4) un- components ( i.e., with immediate-use CSPs, low- intended chemical and physical contaminants, and risk level CSPs, and medium-risk level CSPs) and (5) ingredients of inappropriate quality in com- the achievement of sterility when compounding pounded sterile preparations (CSPs). Contami- with nonsterile ingredients and components (i.e., nated CSPs are potentially most hazardous to pa- with high-risk level CSPs). Some differences be- tients when administered into body cavities, tween standards for sterile compounding in this central nervous and vascular systems, eyes, and chapter and those for nonsterile compounding in joints, and when used as baths for live organs and Pharmaceutical CompoundingNonsterile Prepa- tissues. When CSPs contain excessive bacterial en- rations 795 include, but are not limited to, ISO- dotoxins (see Bacterial Endotoxins Test 85), they classified air environments (see Table 1); person- are potentially most hazardous to patients when nel garbing and gloving; personnel training and administered into the central nervous system. testing in principles and practices of aseptic ma- Despite the extensive attention in this chapter to nipulations and sterilization; environmental quality the provision, maintenance, and evaluation of air specifications and monitoring; and disinfection of quality, the avoidance of direct or physical contact gloves and surfaces of ISO Class 5 (see Table 1) contamination is paramount. It is generally ac- sources. knowledged that direct or physical contact of criti- cal sites of CSPs with contaminants, especially mi- crobial sources, poses the greatest probability of risk to patients. Therefore, compounding personnel must be meticulously conscientious in precluding contact contamination of CSPs both within and outside ISO Class 5 (see Table 1) areas. To achieve the above five conditions and prac- tices, this chapter provides minimum practice and Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 2 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Table 1. ISO Classification of Particulate Mat- thalmic drops and ointments, and tissue ter in Room Air (limits are in particles of 0.5 implants. m and larger per cubic meter [current ISO] and (2) Manufactured sterile products that are either cubic feet [former Federal Standard No. 209E, prepared strictly according to the instructions FS 209E]) * appearing in manufacturers approved label- ing (product package inserts) or prepared dif- Class Name Particle Count ferently than published in such labeling. FS [NOTEThe FDA states that Compounding ISO U.S. FS 209E, does not include mixing, reconstituting, or Class 209E ISO, m 3 ft 3 similar acts that are performed in accordance 3 Class 1 35.2 1 with the directions contained in approved la- 4 Class 10 352 10 beling provided by the products manufac- 5 Class 100 3,520 100 turer and other manufacturer directions con- 6 Class 1,000 35,200 1,000 sistent with that labeling [(21 USC 321 (k) 7 Class10,000 352,000 10,000 and (m)]. However, the FDA-approved label- 8 Class100,000 3,520,000 100,000 ing (product package insert) rarely describes * Adapted from former Federal Standard No. 209E, General Servic- environmental quality (e.g., ISO Class air des- es Administration, Washington, DC, 20407 (September 11, 1992) ignation, exposure durations to non-ISO and ISO 14644-1: 1999, Cleanrooms and associated controlled en- vironmentsPart 1: Classification of air cleanliness. For example, classified air, personnel garbing and gloving, 3,520 particles of 0.5 m per m 3 or larger (ISO Class 5) is equiva- and other aseptic precautions by which sterile lent to 100 particles per ft 3 (Class 100) (1 m 3 =35.2 ft 3 ). products are to be prepared for administra- The standards in this chapter are intended to ap- tion). Beyond-use exposure and storage dates ply to all persons who prepare CSPs and all places or times (see General Notices and Require- where CSPs are prepared (e.g., hospitals and other ments and Pharmaceutical Compound- healthcare institutions, patient treatment clinics, ingNonsterile Preparations 795) for ster- pharmacies, physicians practice facilities, and ile products that have been either opened or other locations and facilities in which CSPs are prepared for administration are not specified prepared, stored, and transported). Persons who in all package inserts for all sterile products. perform sterile compounding include pharmacists, Furthermore, when such durations are speci- nurses, pharmacy technicians, and physicians. fied, they may refer to chemical stability and These terms recognize that most sterile compound- not necessarily to microbiological purity or ing is performed by or under the supervision of safety.] pharmacists in pharmacies and also that this chap- ter applies to all healthcare personnel who prepare, ORGANIZATION OF THIS CHAPTER store, and transport CSPs. For the purposes of this chapter, CSPs include any of the following: The sections in this chapter are organized to fa- (1) Compounded biologics, diagnostics, drugs, cilitate the practitioners understanding of the fun- nutrients, and radiopharmaceuticals, including damental accuracy and quality practices for pre- but not limited to the following dosage forms paring CSPs. They provide a foundation for the that must be sterile when they are adminis- development and implementation of essential pro- tered to patients: aqueous bronchial and nasal cedures for the safe preparation of low-risk, med- inhalations, baths and soaks for live organs ium-risk, and high-risk level CSPs and immediate- and tissues, injections (e.g., colloidal disper- use CSPs, which are classified according to the po- sions, emulsions, solutions, suspensions), irri- tential for microbial, chemical, and physical con- gations for wounds and body cavities, oph- tamination. The chapter is divided into the follow- ing main sections: Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 3 Definitions entry, CSP labeling, and other high-particulate- generating activities are performed. It is also a Responsibility of Compounding Personnel transition area that (1) provides assurance that CSP Microbial Contamination Risk Levels pressure relationships are constantly maintained so Personnel Training and Evaluation in Aseptic that air flows from clean to dirty areas and (2) re- Manipulation Skills duces the need for the heating, ventilating, and air- Immediate-Use CSPs conditioning (HVAC) control system to respond to Single-Dose and Multiple-Dose Containers large disturbances. 1 Hazardous Drugs as CSPs Radiopharmaceuticals as CSPs Aseptic Processing (see Microbiological Evalu- Allergen Extracts as CSPs ation of Clean Rooms and Other Controlled Envi- Verification of Compounding Accuracy and ronments 1116)A mode of processing pharma- Sterility ceutical and medical products that involves the Environmental Quality and Control separate sterilization of the product and of the Suggested Standard Operating Procedures package (containersclosures or packaging ma- (SOPs) terial for medical devices) and the transfer of the Elements of Quality Control product into the container and its closure under at Verification of Automated Compounding De- least ISO Class 5 (see Table 1) conditions. vices (ACDs) for Parenteral Nutrition Beyond-Use Date (BUD) (see General Notices Compounding and Requirements and Pharmaceutical Com- Finished Preparation Release Checks and poundingNonsterile Preparations 795)For Tests the purpose of this chapter, the date or time after Storage and Beyond-Use Dating which a CSP shall not be stored or transported. Maintaining Sterility, Purity, and Stability of The date is determined from the date or time the Dispensed and Distributed CSPs preparation is compounded. Patient or Caregiver Training Biological Safety Cabinet (BSC)A ventilated Patient Monitoring and Adverse Events cabinet for CSPs, personnel, product, and environ- Reporting mental protection having an open front with in- Quality Assurance (QA) Program ward airflow for personnel protection, downward Abbreviations and Acronyms high-efficiency particulate air (HEPA)-filtered Appendices IV laminar airflow for product protection, and HEPA- The requirements and recommendations in this filtered exhausted air for environmental protection. chapter are summarized in Appendix I. A list of ab- Buffer AreaAn area where the primary engi- breviations and acronyms is included at the end of neering control (PEC) is physically located. Activ- the main text, before the Appendices. ities that occur in this area include the preparation All personnel who prepare CSPs shall be re- and staging of components and supplies used when sponsible for understanding these fundamental compounding CSPs. practices and precautions, for developing and im- plementing appropriate procedures, and for contin- Clean Room (see Microbiological Evaluation of ually evaluating these procedures and the quality Clean Rooms and Other Controlled Environments of final CSPs to prevent harm. 1116 and also the definition of Buffer Area)A room in which the concentration of airborne parti- cles is controlled to meet a specified airborne par- DEFINITIONS ticulate cleanliness class. Microorganisms in the Ante-AreaAn ISO Class 8 (see Table 1) or environment are monitored so that a microbial better area where personnel hand hygiene and 1 See American Society of Heating, Refrigerating and Air-Condi- garbing procedures, staging of components, order tioning Engineers, Inc. (ASHRAE), Laboratory Design Guide. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 4 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin level for air, surface, and personnel gear are not exposed to unidirectional HEPA-filtered air, also exceeded for a specified cleanliness class. known as first air. Compounding Aseptic Containment Isolator DisinfectantAn agent that frees from infec- (CACI)A compounding aseptic isolator (CAI) tion, usually a chemical agent but sometimes a designed to provide worker protection from expo- physical one, and that destroys disease-causing sure to undesirable levels of airborne drug pathogens or other harmful microorganisms but throughout the compounding and material transfer may not kill bacterial and fungal spores. It refers to processes and to provide an aseptic environment substances applied to inanimate objects. for compounding sterile preparations. Air ex- First AirThe air exiting the HEPA filter in a change with the surrounding environment should unidirectional air stream that is essentially particle not occur unless the air is first passed through a free. microbial retentive filter (HEPA minimum) system Hazardous DrugsDrugs are classified as haz- capable of containing airborne concentrations of ardous if studies in animals or humans indicate the physical size and state of the drug being com- that exposures to them have a potential for causing pounded. Where volatile hazardous drugs are pre- cancer, developmental or reproductive toxicity, or pared, the exhaust air from the isolator should be harm to organs. (See current NIOSH publication.) appropriately removed by properly designed build- Labeling [see General Notices and Require- ing ventilation. ments and 21 USC 321 (k) and (m)]A term that Compounding Aseptic Isolator (CAI)A designates all labels and other written, printed, or form of isolator specifically designed for com- graphic matter on an immediate container of an ar- pounding pharmaceutical ingredients or prepara- ticle or preparation or on, or in, any package or tions. It is designed to maintain an aseptic com- wrapper in which it is enclosed, except any outer pounding environment within the isolator shipping container. The term label designates throughout the compounding and material transfer that part of the labeling on the immediate processes. Air exchange into the isolator from the container. surrounding environment should not occur unless Media-Fill Test (see Microbiological Evalua- the air has first passed through a microbially reten- tion of Clean Rooms and Other Controlled Envi- tive filter (HEPA minimum). 2 ronments 1116)A test used to qualify aseptic Critical AreaAn ISO Class 5 (see Table 1) technique of compounding personnel or processes environment. and to ensure that the processes used are able to Critical SiteA location that includes any com- produce sterile product without microbial contami- ponent or fluid pathway surfaces (e.g., vial septa, nation. During this test, a microbiological growth injection ports, beakers) or openings (e.g., opened medium such as SoybeanCasein Digest Medium ampuls, needle hubs) exposed and at risk of direct is substituted for the actual drug product to simu- contact with air (e.g., ambient room or HEPA fil- late admixture compounding. 3 The issues to con- tered), moisture (e.g., oral and mucosal secre- sider in the development of a media-fill test are tions), or touch contamination. Risk of microbial media-fill procedures, media selection, fill volume, particulate contamination of the critical site in- incubation, time and temperature, inspection of creases with the size of the openings and exposure filled units, documentation, interpretation of re- time. sults, and possible corrective actions required. Direct Compounding Area (DCA)A critical Multiple-Dose Container (see General Notices area within the ISO Class 5 (see Table 1) primary and Requirements and Containers for Injections engineering control (PEC) where critical sites are under Injections 1)A multiple-unit container 2 CETA Applications Guide for the Use of Compounding Isolators in Compounding Sterile Preparations in Healthcare Facilities, CAG- 3 U.S. Food and Drug Administration, Guidance for Industry, Sterile 001-2005, Controlled Environment Testing Association (CETA), Drug Products Produced by Aseptic ProcessingCurrent Good November 8, 2005. Manufacturing Practice, September 2004. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 5 for articles or preparations intended for parenteral suant to the order of a licensed prescriber; the arti- administration only and usually containing antimi- cle may or may not contain sterile products. crobial preservatives. The beyond-use date (BUD) ProductA commercially manufactured sterile for an opened or entered (e.g., needle-punctured) drug or nutrient that has been evaluated for safety multiple-dose container with antimicrobial pre- and efficacy by the FDA. Products are accompa- servatives is 28 days (see Antimicrobial Effective- nied by full prescribing information, which is com- ness Testing 51), unless otherwise specified by monly known as the FDA-approved manufactur- the manufacturer. ers labeling or product package insert. Negative Pressure RoomA room that is at a Positive Pressure RoomA room that is at a lower pressure than the adjacent spaces and, there- higher pressure than the adjacent spaces and, fore, the net flow of air is into the room. 1 therefore, the net airflow is out of the room. 1 Pharmacy Bulk Package (see Containers for Single-Dose Container (see General Notices Injections under Injections 1)A container of a and Requirements and Containers for Injections sterile preparation for parenteral use that contains under Injections 1)A single-dose container is a many single doses. The contents are intended for single-unit container for articles (see General No- use in a pharmacy admixture program and are re- tices and Requirements) or preparations intended stricted to the preparation of admixtures for infu- for parenteral administration only. It is intended sion or, through a sterile transfer device, for the for a single use. A single-dose container is labeled filling of empty sterile syringes. The closure shall as such. Examples of single-dose containers in- be penetrated only one time after constitution with clude prefilled syringes, cartridges, fusion-sealed a suitable sterile transfer device or dispensing set, containers, and closure-sealed containers when so which allows measured dispensing of the contents. labeled. The pharmacy bulk package is to be used only in a Segregated Compounding AreaA designated suitable work area such as a laminar flow hood (or space, either a demarcated area or room, that is re- an equivalent clean air compounding area). stricted to preparing low-risk level CSPs with 12- Where a container is offered as a pharmacy bulk hour or less BUD. Such area shall contain a device package, the label shall (a) state prominently that provides unidirectional airflow of ISO Class 5 Pharmacy Bulk PackageNot for Direct Infu- (see Table 1) air quality for preparation of CSPs sion, (b) contain or refer to information on proper and shall be void of activities and materials that techniques to help ensure safe use of the product, are extraneous to sterile compounding. and (c) bear a statement limiting the time frame in Sterilizing Grade MembranesMembranes which the container may be used once it has been that are documented to retain 100% of a culture of entered, provided it is held under the labeled stor- 10 7 microorganisms of a strain of Brevundimonas age conditions. (Pseudomonas) diminuta per square centimeter of Primary Engineering Control (PEC)A de- membrane surface under a pressure of not less than vice or room that provides an ISO Class 5 (see Ta- 30 psi (2.0 bar). Such filter membranes are nomi- ble 1) environment for the exposure of critical sites nally at 0.22-m or 0.2-m nominal pore size, de- when compounding CSPs. Such devices include, pending on the manufacturers practice. but may not be limited to, laminar airflow work- Sterilization by FiltrationPassage of a fluid benches (LAFWs), biological safety cabinets or solution through a sterilizing grade membrane (BSCs), compounding aseptic isolators (CAIs), to produce a sterile effluent. and compounding aseptic containment isolators (CACIs). Terminal SterilizationThe application of a PreparationA preparation, or a CSP, that is a lethal process (e.g., steam under pressure or sterile drug or nutrient compounded in a licensed autoclaving) to sealed containers for the purpose pharmacy or other healthcare-related facility pur- of achieving a predetermined sterility assurance Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 6 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin level of usually less than 10 6 , or a probability of correctly perform and document the following less than one in one million of a nonsterile unit. 3 activities in their sterile compounding duties: a. perform antiseptic hand cleansing and Unidirectional Flow (see footnote 3)An air- disinfection of nonsterile compounding flow moving in a single direction in a robust and surfaces; uniform manner and at sufficient speed to b. select and appropriately don protective reproducibily sweep particles away from the criti- garb; cal processing or testing area. c. maintain or achieve sterility of CSPs in ISO Class 5 (see Table 1) PEC devices RESPONSIBILITY OF COMPOUNDING and protect personnel and compounding PERSONNEL environments from contamination by ra- Compounding personnel are responsible for en- dioactive, cytotoxic, and chemotoxic suring that CSPs are accurately identified, meas- drugs (see Hazardous Drugs as CSPs and ured, diluted, and mixed and are correctly purified, Radiopharmaceuticals as CSPs); sterilized, packaged, sealed, labeled, stored, dis- d. identify, weigh, and measure ingredients; pensed, and distributed. These performance re- and sponsibilities include maintaining appropriate e. manipulate sterile products aseptically, cleanliness conditions and providing labeling and sterilize high-risk level CSPs, and label supplementary instructions for the proper clinical and quality inspect CSPs. administration of CSPs. 2. Ingredients have their correct identity, quality, Compounding supervisors shall ensure, through and purity. either direct measurement or appropriate informa- 3. Opened or partially used packages of ingredi- tion sources, that specific CSPs maintain their la- ents for subsequent use in CSPs are properly beled strength within monograph limits for USP stored under restricted access conditions in articles, or within 10% if not specified, until their the compounding facility. Such packages can- BUDs. All CSPs are prepared in a manner that not be used when visual inspection detects un- maintains sterility and minimizes the introduction authorized breaks in the container, closure, of particulate matter. and seal; when the contents do not possess the A written quality assurance procedure includes expected appearance, aroma, and texture; the following in-process checks that are applied, as when the contents do not pass identification appropriate, to specific CSPs: accuracy and preci- tests specified by the compounding facility; sion of measuring and weighing; the requirement and when either the BUD or expiration date for sterility; methods of sterilization and purifica- has been exceeded. tion; safe limits and ranges for strength of ingredi- 4. Water-containing CSPs that are nonsterile ents, bacterial endotoxins, and particulate matter; during any phase of the compounding proce- pH; labeling accuracy and completeness; BUD as- dure are sterilized within 6 hours after com- signment; and packaging and storage require- pleting the preparation in order to minimize ments. The dispenser shall, when appropriate and the generation of bacterial endotoxins. practicable, obtain and evaluate results of testing 5. Sterilization methods achieve sterility of for identity, strength, purity, and sterility before a CSPs while maintaining the labeled strength CSP is dispensed. Qualified licensed healthcare of active ingredients and the physical integrity professionals who supervise compounding and dis- of packaging. pensing of CSPs shall ensure that the following 6. Measuring, mixing, sterilizing, and purifying objectives are achieved: devices are clean, appropriately accurate, and 1. Compounding personnel are adequately effective for their intended use. skilled, educated, instructed, and trained to 7. Potential harm from added substances and Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 7 differences in rate and extent of bioavailabil- the skill and knowledge of personnel who prepare ity of active ingredients for other than oral CSPs. The rigor of in-process quality-control route of administration are carefully evaluated checks and of postcompounding quality inspection before such CSPs are dispensed and and testing increases with the potential hazard of administered. the route of administration. For example, nonste- 8. Packaging selected for CSPs is appropriate to rility, excessive bacterial endotoxin contamination, preserve the sterility and strength until the large errors in strength of correct ingredients, and BUD. incorrect ingredients in CSPs are potentially more 9. While being used, the compounding environ- dangerous to patients when the CSPs are adminis- ment maintains the sterility or the presteriliza- tered into the vascular and central nervous systems tion purity, whichever is appropriate, of the than when administered by most other routes. CSP. 10. Labels on CSPs list the names and amounts or CSP MICROBIAL CONTAMINATION RISK concentrations of active ingredients, and the LEVELS labels or labeling of injections (see Preserva- The three contamination categories for CSPs de- tion, Packaging, Storage, and Labeling in the scribed in this section are assigned primarily ac- General Notices and Requirements) list the cording to the potential for microbial contamina- names and amounts or concentrations of all tion during the compounding of low-risk level ingredients (see Injections 1). Before being CSPs and medium-risk level CSPs or the potential dispensed or administered, the clarity of solu- for not sterilizing high-risk level CSPs, any of tions is visually confirmed; also, the identity which would subject patients to risk of harm, in- and amounts of ingredients, procedures to cluding death. High-risk level CSPs must be steril- prepare and sterilize CSPs, and specific re- ized before being administered to patients. The ap- lease criteria are reviewed to ensure their ac- propriate risk levellow, medium, or highis curacy and completeness. assigned according to the corresponding probabil- 11. BUDs are assigned on the basis of direct test- ity of contaminating a CSP with (1) microbial con- ing or extrapolation from reliable literature tamination (e.g., microbial organisms, spores, en- sources and other documentation (see Stabil- dotoxins) and (2) chemical and physical ity Criteria and Beyond-Use Dating under contamination (e.g., foreign chemicals, physical Pharmaceutical CompoundingNonsterile matter). Potential sources of contamination in- Preparations 795). clude, but are not limited to, solid and liquid mat- 12. Procedures for measuring, mixing, dilution, ter from compounding personnel and objects; non- purification, sterilization, packaging, and la- sterile components employed and incorporated beling conform to the correct sequence and before terminal sterilization; inappropriate condi- quality established for the specified CSP. tions within the restricted compounding environ- 13. Deficiencies in compounding, labeling, pack- ment; prolonged presterilization procedures with aging, and quality testing and inspection can aqueous preparations; and nonsterile dosage forms be rapidly identified and corrected. used to compound CSPs. 14. When time and personnel availability so per- mit, compounding manipulations and proce- The characteristics described below for low-, dures are separated from postcompounding medium-, and high-risk level CSPs are intended as quality inspection and review before CSPs are a guide to the breadth and depth of care necessary dispensed. in compounding, but they are neither exhaustive This chapter emphasizes the need to maintain nor prescriptive. The licensed healthcare profes- high standards for the quality and control of sionals who supervise compounding are responsi- processes, components, and environments and for ble for determining the procedural and environ- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 8 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin mental quality practices and attributes that are 4. For a low-risk level preparation, in the ab- necessary for the risk level they assign to specific sence of passing a sterility test (see Sterility CSPs. Tests 71), the storage periods cannot exceed the following time periods: before administra- These risk levels apply to the quality of CSPs tion, the CSPs are properly stored and are ex- immediately after the final aseptic mixing or fill- posed for not more than 48 hours at controlled ing or immediately after the final sterilization, un- room temperature (see General Notices and less precluded by the specific characteristics of the Requirements), for not more than 14 days at a preparation. Upon subsequent storage and shipping cold temperature (see General Notices and of freshly finished CSPs, an increase in the risks of Requirements), and for 45 days in solid frozen chemical degradation of ingredients, contamina- state between 25 and 10. tion from physical damage to packaging, and per- meability of plastic and elastomeric packaging is Examples of Low-Risk Compounding expected. In such cases, compounding personnel 1. Single-volume transfers of sterile dosage are responsible for considering the potential addi- forms from ampuls, bottles, bags, and vials tional risks to the integrity of CSPs when assigning using sterile syringes with sterile needles, BUDs. The pre-administration storage duration other administration devices, and other sterile and temperature limits specified in the following containers. The solution content of ampuls subsections apply in the absence of direct sterility should be passed through a sterile filter to re- testing results that justify different limits for spe- move any particles. cific CSPs. 2. Simple aseptic measuring and transferring with not more than three packages of manu- Low-Risk Level CSPs factured sterile products, including an infu- sion or diluent solution to compound drug ad- CSPs compounded under all the following con- mixtures and nutritional solutions. ditions are at a low risk of contamination. Low-Risk Level CSPs with 12-Hour or Less Low-Risk Conditions BUDIf the PEC is a CAI or CACI that does not 1. The CSPs are compounded with aseptic ma- meet the requirements described in Placement of nipulations entirely within ISO Class 5 (see Primary Engineering Controls or is a laminar air- Table 1) or better air quality using only sterile flow workbench (LAFW) or a biological safety ingredients, products, components, and cabinet (BSC) that cannot be located within an devices. ISO Class 7 (see Table 1) buffer area, then only 2. The compounding involves only transfer, low-risk level nonhazardous and radi- measuring, and mixing manipulations using opharmaceutical CSPs pursuant to a physicians not more than three commercially manufac- order for a specific patient may be prepared, and tured packages of sterile products and not administration of such CSPs shall commence more than two entries into any one sterile within 12 hours of preparation or as recommended container or package (e.g., bag, vial) of sterile in the manufacturers package insert, whichever is product or administration container/device to less. Low-risk level CSPs with a 12-hour or less prepare the CSP. BUD shall meet all of the following four criteria: 3. Manipulations are limited to aseptically open- ing ampuls, penetrating disinfected stoppers 1. PECs (LAFWs, BSCs, CAIs, CACIs,) shall on vials with sterile needles and syringes, and be certified and maintain ISO Class 5 (see Ta- transferring sterile liquids in sterile syringes ble 1) as described in Facility Design and En- to sterile administration devices, package con- vironmental Controls for exposure of critical tainers of other sterile products, and con- sites and shall be in a segregated compound- tainers for storage and dispensing. ing area restricted to sterile compounding ac- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 9 tivities that minimize the risk of CSP 3. Review of all orders and packages of ingredi- contamination. ents to ensure that the correct identity and 2. The segregated compounding area shall not amounts of ingredients were compounded. be in a location that has unsealed windows or 4. Visual inspection of CSPs to ensure the ab- doors that connect to the outdoors or high sence of particulate matter in solutions, the traffic flow, or that is adjacent to construction absence of leakage from vials and bags, and sites, warehouses, or food preparation. Note the accuracy and thoroughness of labeling. that this list is not intended to be all Media-Fill Test ProcedureThis test or an inclusive. equivalent test is performed at least annually by 3. Personnel shall follow the procedures de- each person authorized to compound in a low-risk scribed in Personnel Cleansing and Garbing level environment under conditions that closely and Additional Personnel Requirements prior simulate the most challenging or stressful condi- to compounding. Sinks should not be located tions encountered during compounding of low-risk adjacent to the ISO Class 5 (see Table 1) level CSPs. Once begun, this test is completed PEC. Sinks should be separated from the im- without interruption. Example of test procedure: mediate area of the ISO Class 5 (see Table 1) within an ISO Class 5 (see Table 1) air quality en- PEC device. vironment, three sets of four 5-mL aliquots of ster- 4. The specifications in Cleaning and Disinfect- ile SoybeanCasein Digest Medium (also known ing the Sterile Compounding Areas, Person- as trypticase soy broth or trypticase soy agar nel Training and Competency Evaluation of [TSA]) are transferred with the same sterile 10-mL Garbing, Aseptic Work Practices and Clean- syringe and vented needle combination into separ- ing/Disinfection Procedures, and Viable and ate sealed, empty, sterile 30-mL clear vials (i.e., Nonviable Environmental Sampling (ES) four 5-mL aliquots into each of three 30-mL vials). Testing shall be followed as described in the Sterile adhesive seals are aseptically affixed to the chapter. rubber closures on the three filled vials, then the Compounding personnel must recognize that the vials are incubated at 20 to 25 or at 30 to 35 absence of an ISO Class 7 (see Table 1) buffer for a minimum of 14 days. If two temperatures are area environment in a general uncontrolled envi- used for incubation of media-filled samples, then ronment increases the potential of microbial con- these filled containers should be incubated for at tamination, and administration durations of least 7 days at each temperature (see Microbiologi- microbially contaminated CSPs exceeding a few cal Evaluation of Clean Rooms and Other Con- hours increase the potential for clinically signifi- trolled Environments 1116). Inspect for micro- cant microbial colonization, and thus for patient bial growth over 14 days as described in Personnel harm, especially in critically ill or immunocom- Training and Competency Evaluation of Garbing, promised patients. Aseptic Work Practices and Cleaning/Disinfection Quality AssuranceQuality assurance prac- Procedures. tices include, but are not limited to the following: 1. Routine disinfection and air quality testing of Medium-Risk Level CSPs the direct compounding environment to mini- When CSPs are compounded aseptically under mize microbial surface contamination and Low-Risk Conditions and one or more of the fol- maintain ISO Class 5 (see Table 1) air quality. lowing conditions exists, such CSPs are at a med- 2. Visual confirmation that compounding per- ium risk of contamination. sonnel are properly donning and wearing ap- Medium-Risk Conditions propriate items and types of protective gar- ments, including eye protection and face 1. Multiple individual or small doses of sterile masks. products are combined or pooled to prepare a Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 10 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin CSP that will be administered either to multi- vironment, six 100-mL aliquots of sterile ple patients or to one patient on multiple SoybeanCasein Digest Medium are aseptically occasions. transferred by gravity through separate tubing sets 2. The compounding process includes complex into separate evacuated sterile containers. The six aseptic manipulations other than the single- containers are then arranged as three pairs, and a volume transfer. sterile 10-mL syringe and 18-gauge needle combi- 3. The compounding process requires unusually nation is used to exchange two 5-mL aliquots of long duration, such as that required to com- medium from one container to the other container plete dissolution or homogeneous mixing. in the pair. For example, after a 5-mL aliquot from 4. For a medium-risk preparation, in the absence the first container is added to the second container of passing a sterility test (see Sterility Tests in the pair, the second container is agitated for 10 71), the storage periods cannot exceed the seconds, then a 5-mL aliquot is removed and re- following time periods: before administration, turned to the first container in the pair. The first the CSPs are properly stored and are exposed container is then agitated for 10 seconds, and the for not more than 30 hours at controlled room next 5-mL aliquot is transferred from it back to the temperature (see General Notices and Re- second container in the pair. Following the two quirements), for not more than 9 days at a 5-mL aliquot exchanges in each pair of containers, cold temperature (see General Notices and a 5-mL aliquot of medium from each container is Requirements), and for 45 days in solid frozen aseptically injected into a sealed, empty, sterile state between 25 and 10. 10-mL clear vial, using a sterile 10-mL syringe Examples of Medium-Risk Compounding and vented needle. Sterile adhesive seals are asep- 1. Compounding of total parenteral nutrition flu- tically affixed to the rubber closures on the three ids using manual or automated devices during filled vials, then the vials are incubated at 20 to which there are multiple injections, detach- 25 or at 30 to 35 for a minimum of 14 days. If ments, and attachments of nutrient source two temperatures are used for incubation of media- products to the device or machine to deliver filled samples, then these filled containers should all nutritional components to a final sterile be incubated for at least 7 days at each temperature container. (see Microbiological Evaluation of Clean Rooms 2. Filling of reservoirs of injection and infusion and Other Controlled Environments 1116). In- devices with more than three sterile drug spect for microbial growth over 14 days as de- products and evacuation of air from those res- scribed in Personnel Training and Competency ervoirs before the filled device is dispensed. Evaluation of Garbing, Aseptic Work Practices 3. Transfer of volumes from multiple ampuls or and Cleaning/Disinfection Procedures. vials into one or more final sterile containers. Quality AssuranceQuality assurance proce- High-Risk Level CSPs dures for medium-risk level CSPs include all those CSPs compounded under any of the following for low-risk level CSPs, as well as a more chal- conditions are either contaminated or at a high risk lenging media-fill test passed annually or more to become contaminated. frequently. High-Risk Conditions Media-Fill Test ProcedureThis test or an 1. Nonsterile ingredients, including manufac- equivalent test is performed at least annually under tured products not intended for sterile routes conditions that closely simulate the most challeng- of administration (e.g., oral), are incorporated ing or stressful conditions encountered during or a nonsterile device is employed before ter- compounding. Once begun, this test is completed minal sterilization. without interruption. Example of test procedure: within an ISO Class 5 (see Table 1) air quality en- 2. Any of the following are exposed to air qual- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 11 ity worse than ISO Class 5 (see Table 1) for matter. Sterilization of high-risk level CSPs by fil- more than 1 hour (see Immediate-Use tration shall be performed with a sterile 0.2-m or CSPs): 0.22-m nominal pore size filter entirely within an sterile contents of commercially manu- ISO Class 5 (see Table 1) or superior air quality factured products, environment. CSPs that lack effective antimicrobial Examples of High-Risk Conditions preservatives, and 1. Dissolving nonsterile bulk drug and nutrient sterile surfaces of devices and containers powders to make solutions that will be termi- for the preparation, transfer, sterilization, nally sterilized. and packaging of CSPs. 2. Exposing the sterile ingredients and compo- 3. Compounding personnel are improperly nents used to prepare and package CSPs to garbed and gloved (see Personnel Cleansing room air quality worse than ISO Class 5 (see and Use of Barrier Protective Equipment). Table 1) for more than 1 hour (see Immediate- 4. Nonsterile water-containing preparations are Use CSPs). stored for more than 6 hours before being 3. Measuring and mixing sterile ingredients in sterilized. nonsterile devices before sterilization is 5. It is assumed, and not verified by examination performed. of labeling and documentation from suppliers 4. Assuming, without appropriate evidence or or by direct determination, that the chemical direct determination, that packages of bulk in- purity and content strength of ingredients gredients contain at least 95% by weight of meet their original or compendial specifica- their active chemical moiety and have not tions in unopened or in opened packages of been contaminated or adulterated between bulk ingredients (see Ingredient Selection uses. under Pharmaceutical CompoundingNon- Quality AssuranceQuality assurance proce- sterile Preparations 795). dures for high-risk level CSPs include all those for For a sterilized high-risk level preparation, in the low-risk level CSPs. In addition, a media-fill test absence of passing a sterility test, the storage pe- that represents high-risk level compounding is per- riods cannot exceed the following time periods: formed semiannually by each person authorized to before administration, the CSPs are properly compound high-risk level CSPs. stored and are exposed for not more than 24 hours Media-Fill Test Procedure for CSPs Sterilized at controlled room temperature (see General No- by FiltrationThis test or an equivalent test is tices and Requirements), for not more than 3 days performed under conditions that closely simulate at a cold temperature (see General Notices and Re- the most challenging or stressful conditions en- quirements), and for 45 days in solid frozen state countered when compounding high-risk level between 25 and 10. [NOTESterility tests for CSPs. Once begun, this test is completed without autoclaved CSPs are not required unless they are interruption. Example of test procedure (in the fol- prepared in batches of more than 25 units.] lowing sequence): All nonsterile measuring, mixing, and purifying 1. Dissolve 3g of nonsterile commercially avail- devices are rinsed thoroughly with sterile, pyro- able SoybeanCasein Digest Medium in 100 gen-free water, and then thoroughly drained or mL of nonbacteriostatic water to make a 3% dried immediately before use for high-risk com- nonsterile solution. pounding. All high-risk level CSP solutions sub- jected to terminal sterilization are prefiltered by 2. Draw 25 mL of the medium into each of three passing through a filter with a nominal pore size 30-mL sterile syringes. Transfer 5 mL from not larger than 1.2 m preceding or during filling each syringe into separate sterile 10-mL vials. into their final containers to remove particulate These vials are the positive controls to gener- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 12 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin ate exponential microbial growth, which is in- Media-Fill Challenge TestingThe skill of dicated by visible turbidity upon incubation. personnel to aseptically prepare CSPs may be evaluated using sterile fluid bacterial culture me- 3. Under aseptic conditions and using aseptic dia-fill verification 3 (i.e., sterile bacterial culture techniques, affix a sterile 0.2-m or 0.22-m medium transfer via a sterile syringe and needle). nominal pore size filter unit and a 20-gauge Media-fill testing is used to assess the quality of needle to each syringe. Inject the next 10 mL the aseptic skill of compounding personnel. Me- from each syringe into three separate 10-mL dia-fill tests represent the most challenging or sterile vials. Repeat the process for three more stressful conditions actually encountered by the vials. Label all vials, affix sterile adhesive personnel being evaluated when they prepare par- seals to the closure of the nine vials, and incu- ticular risk level CSPs and when sterilizing high- bate them at 20 to 25 or at 30 to 35 for a risk level CSPs. Media-fill challenge tests that minimum of 14 days. If two temperatures are simulate high-risk level compounding are also used for incubation of media-filled samples, used to verify the capability of the compounding then these filled containers should be incu- environment and process to produce a sterile bated for at least 7 days at each temperature preparation. (see Microbiological Evaluation of Clean Rooms and Other Controlled Environments Commercially available sterile fluid culture me- 1116). Inspect for microbial growth over 14 dia, such as SoybeanCasein Digest Medium (see days as described in Personnel Training and Sterility Tests 71), shall be able to promote expo- Competency Evaluation of Garbing, Aseptic nential colonization of bacteria that are most likely Work Practices and Cleaning/Disinfection to be transmitted to CSPs from the compounding Procedures. personnel and environment. Media-filled vials are generally incubated at 20 to 25 or at 30 to 35 for a minimum of 14 days. If two temperatures are PERSONNEL TRAINING AND used for incubation of media-filled samples, then EVALUATION IN ASEPTIC these filled containers should be incubated for at MANIPULATION SKILLS least 7 days at each temperature (see Microbiologi- Personnel who prepare CSPs shall be trained cal Evaluation of Clean Rooms and Other Con- conscientiously and skillfully by expert personnel trolled Environments 1116). Failure is indicated and through audiovideo instructional sources and by visible turbidity in the medium on or before 14 professional publications in the theoretical princi- days. ples and practical skills of aseptic manipulations and in achieving and maintaining ISO Class 5 (see IMMEDIATE-USE CSPs Table 1) environmental conditions before they be- gin to prepare CSPs. Compounding personnel shall The immediate-use provision is intended only perform didactic review and pass written and me- for those situations where there is a need for emer- dia-fill testing of aseptic manipulative skills ini- gency or immediate patient administration of a tially, at least annually thereafter for low- and CSP. Such situations may include cardiopulmo- medium-risk level compounding, and semiannu- nary resuscitation, emergency room treatment, ally for high-risk level compounding. Compound- preparation of diagnostic agents, or critical therapy ing personnel who fail written tests or whose me- where the preparation of the CSP under conditions dia-fill test vials result in gross microbial described for Low-Risk Level CSPs subjects the colonization shall be immediately re-instructed patient to additional risk due to delays in therapy. and re-evaluated by expert compounding person- Immediate-use CSPs are not intended for storage nel to ensure correction of all aseptic practice for anticipated needs or batch compounding. Prep- deficiencies. arations that are medium-risk level and high-risk Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 13 level CSPs shall not be prepared as immediate-use significant microbial colonization and thus for pa- CSPs. tient harm, especially in critically ill or immu- Immediate-use CSPs are exempt from the re- nocompromised patients. quirements described for Low-Risk Level CSPs SINGLE-DOSE AND MULTIPLE-DOSE only when all of the following criteria are met: CONTAINERS 1. The compounding process involves simple transfer of not more than three commercially Opened or needle-punctured single-dose con- manufactured packages of sterile nonhazard- tainers, such as bags, bottles, syringes, and vials of ous products or diagnostic radiopharmaceuti- sterile products and CSPs shall be used within 1 cal products from the manufacturers original hour if opened in worse than ISO Class 5 (see Ta- containers and not more than two entries into ble 1) air quality (see Immediate-Use CSPs), and any one container or package (e.g., bag, vial) any remaining contents must be discarded. Single- of sterile infusion solution or administration dose vials exposed to ISO Class 5 (see Table 1) or container/device. For example, anti-neoplas- cleaner air may be used up to 6 hours after initial tics shall not be prepared as immediate-use needle puncture. Opened single-dose ampuls shall CSPs because they are hazardous drugs. not be stored for any time period. Multiple-dose 2. Unless required for the preparation, the com- containers (e.g., vials) are formulated for removal pounding procedure is a continuous process of portions on multiple occasions because they not to exceed 1 hour. usually contain antimicrobial preservatives. The 3. During preparation, aseptic technique is fol- BUD after initially entering or opening (e.g., nee- lowed and, if not immediately administered, dle-punctured) multiple-dose containers is 28 days the finished CSP is under continuous supervi- (see Antimicrobial Effectiveness Testing 51) un- sion to minimize the potential for contact with less otherwise specified by the manufacturer. nonsterile surfaces, introduction of particulate matter or biological fluids, mix-ups with other HAZARDOUS DRUGS AS CSPs CSPs, and direct contact of outside surfaces. 4. Administration begins not later than 1 hour Although the potential therapeutic benefits of following the start of the preparation of the compounded sterile hazardous drug preparations CSP. generally outweigh the risks of their adverse ef- 5. Unless immediately and completely adminis- fects in ill patients, exposed healthcare workers tered by the person who prepared it or im- risk similar adverse effects with no therapeutic mediate and complete administration is wit- benefit. Occupational exposure to hazardous drugs nessed by the preparer, the CSP shall bear a can result in (1) acute effects, such as skin rashes; label listing patient identification information, (2) chronic effects, including adverse reproductive the names and amounts of all ingredients, the events; and (3) possibly cancer (see Appendix A of name or initials of the person who prepared NIOSH Publication no. 2004-165). the CSP, and the exact 1-hour BUD and time. Hazardous drugs shall be prepared for adminis- 6. If administration has not begun within 1 hour tration only under conditions that protect the following the start of preparing the CSP, the healthcare workers and other personnel in the CSP shall be promptly, properly, and safely preparation and storage areas. Hazardous drugs discarded. shall be stored separately from other inventory in a Compounding in worse than ISO Class 5 (see manner to prevent contamination and personnel Table 1) conditions increases the likelihood of mi- exposure. Many hazardous drugs have sufficient crobial contamination, and administration dura- vapor pressures that allow volatilization at room tions of microbially contaminated CSPs exceeding temperature; thus storage is preferably within a a few hours increase the potential for clinically containment area such as a negative pressure Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 14 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin room. The storage area should have sufficient gen- cause of their inherent closed system process. In eral exhaust ventilation, at least 12 air changes per facilities that prepare a low volume of hazardous hour (ACPH) 4 to dilute and remove any airborne drugs, the use of two tiers of containment (e.g., contaminants. CSTD within a BSC or CACI that is located in a non-negative pressure room) is acceptable. Hazardous drugs shall be handled with caution at Appropriate personnel protective equipment all times using appropriate chemotherapy gloves (PPE) shall be worn when compounding in a BSC during receiving, distribution, stocking, inventory- or CACI and when using CSTD devices. PPE ing, preparation for administration, and disposal. should include gowns, face masks, eye protection, Hazardous drugs shall be prepared in an ISO Class hair covers, shoe covers or dedicated shoes, double 5 (see Table 1) environment with protective engi- gloving with sterile chemo-type gloves, and com- neering controls in place and following aseptic pliance with manufacturers recommendations practices specified for the appropriate contamina- when using a CACI. tion risk levels defined in this chapter. Access All personnel who compound hazardous drugs shall be limited to areas where drugs are stored shall be fully trained in the storage, handling, and and prepared to protect persons not involved in disposal of these drugs. This training shall occur drug preparation. prior to preparing or handling hazardous CSPs, All hazardous drugs shall be prepared in a BSC 5 and its effectiveness shall be verified by testing or a CACI that meets or exceeds the standards for specific hazardous drugs preparation techniques. CACI in this chapter. The ISO Class 5 (see Table Such verification shall be documented for each 1) BSC or CACI shall be placed in an ISO Class 7 person at least annually. This training shall include (seeTable 1) area that is physically separated (i.e., didactic overview of hazardous drugs, including a different area from other preparation areas) and mutagenic, teratogenic, and carcinogenic proper- optimally has not less than 0.01-inch water column ties, and it shall include ongoing training for each negative pressure to adjacent positive pressure ISO new hazardous drug that enters the marketplace. Class 7 (see Table 1) or better ante-areas, thus pro- Compounding personnel of reproductive capability viding inward airflow to contain any airborne shall confirm in writing that they understand the drug. A pressure indicator shall be installed that risks of handling hazardous drugs. The training can be readily monitored for correct room pressur- shall include at least the following: (1) safe aseptic ization. The BSC and CACI optimally should be manipulation practices; (2) negative pressure tech- 100% vented to the outside air through HEPA niques when utilizing a BSC or CACI; (3) correct filtration. use of CSTD devices; (4) containment, cleanup, If a CACI that meets the requirements of this and disposal procedures for breakages and spills; chapter is used outside of a buffer area, the com- and (5) treatment of personnel contact and inhala- pounding area shall maintain a minimum negative tion exposure. pressure of 0.01-inch water column and have a NOTEBecause standards of assay and unac- minimum of 12 ACPHs. ceptable quantities of contamination of each drug When closed-system vial-transfer devices have not been established in the literature, the fol- (CSTDs) (i.e., vial-transfer systems that allow no lowing paragraph is a recommendation only. Fu- venting or exposure of hazardous substance to the ture standards will be adopted as these assay environment) are used, they shall be used within methods are developed and proven. the ISO Class 5 (see Table 1) environment of a In order to ensure containment, especially in op- BSC or CACI. The use of a CSTD is preferred be- erations preparing large volumes of hazardous 4 Guidelines for Environmental Infection Control in Health-Care Fa- drugs, environmental sampling to detect uncon- cilities, Recommendations of CDC and the Healthcare Infection Control Practices Advisory Committee (HICPAC), MMWR, vol. tained hazardous drugs should be performed rou- 52, no. RR-10, J une 6, 2003, figure 3, pg. 12. 5 NSF/ANSI 49. tinely (e.g., initially as a benchmark and at least Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 15 every 6 months or more often as needed to verify or not more than 30 mL taken from a multiple- containment). This sampling should include sur- dose container (see Injections 1) shall be desig- face wipe sampling of the working area of BSCs nated as, and conform to, the standards for Low- and CACIs; counter tops where finished prepara- Risk Level CSPs. tions are placed; areas adjacent to BSCs and These radiopharmaceuticals shall be com- CACIs, including the floor directly under the pounded using appropriately shielded vials and working area; and patient administration areas. syringes in a properly functioning and certified Common marker hazardous drugs that can be as- ISO Class 5 (see Table 1) PEC located in an ISO sayed include cyclophosphamide, ifosfamide, Class 8 (see Table 1) or cleaner air environment to methotrexate, and fluorouracil. If any measurable permit compliance with special handling, shield- contamination (cyclophosphamide levels greater ing, and negative air flow requirements. than 1.00 ng per cm 2 have been found to cause hu- Radiopharmaceutical vials designed for multi- man uptake) is found by any of these quality assur- use, compounded with technetium-99m, exposed ance procedures, practitioners shall make the deci- to ISO Class 5 (see Table 1) environment, and sion to identify, document, and contain the cause punctured by needles with no direct contact con- of contamination. Such action may include retrain- tamination may be used up to the time indicated by ing, thorough cleaning (utilizing high-pH soap and manufacturers recommendations. Storage and water), and improving engineering controls. Ex- transport of properly shielded vials of radi- amples of improving engineering controls are (1) opharmaceutical CSPs may occur in a limited ac- venting BSCs or CACIs 100% to the outside, (2) cess ambient environment without a specific ISO implementing a CSTD, or (3) re-assessing types of class designation. BSCs or CACIs. Technetium-99m/molybdenum-99generator sys- Disposal of all hazardous drug wastes shall com- tems shall be stored and eluted (operated) under ply with all applicable federal and state regu- conditions recommended by manufacturers and lations. All personnel who perform routine custo- applicable state and federal regulations. Such gen- dial waste removal and cleaning activities in erator systems shall be eluted in an ISO Class 8 storage and preparation areas for hazardous drugs (seeTable 1) or cleaner air environment to permit shall be trained in appropriate procedures to pro- special handling, shielding, and air flow require- tect themselves and prevent contamination. ments. To limit acute and chronic radiation expo- sure of inspecting personnel to a level that is as RADIOPHARMACEUTICALS AS CSPs low as reasonably achievable (ALARA), direct visual inspection of radiopharmaceutical CSPs In the case of production of radiopharmaceuti- containing high concentrations of doses of radioac- cals for positron emission tomography (PET), gen- tivity shall be conducted in accordance with eral test chapter Radiopharmaceuticals for Posi- ALARA. tron Emission TomographyCompounding 823 Radiopharmaceuticals prepared as Low-Risk supersedes this chapter. Upon release of a PET Level CSPs with 12-Hour or Less BUD shall be radiopharmaceutical as a finished drug product prepared in a segregated compounding area. A line from a production facility, the further handling, of demarcation defining the segregated compound- manipulation, or use of the product will be consid- ing area shall be established. Materials and garb ered compounding, and the content of this section exposed in a patient care and treatment area shall and chapter is applicable. not cross a line of demarcation into the segregated For the purposes of this chapter, radi- compounding area. opharmaceuticals compounded from sterile com- ponents in closed sterile containers and with a vol- ume of 100 mL or less for a single-dose injection Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 16 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin ALLERGEN EXTRACTS AS CSPs for at least 10 seconds and allowed to dry be- fore they are used to compound allergen ex- Allergen extracts as CSPs are single-dose and tracts as CSPs. multiple-dose intradermal or subcutaneous injec- 9. The aseptic compounding manipulations min- tions that are prepared by specially trained physi- imize direct contact contamination (e.g., from cians and personnel under their direct supervision. glove fingertips, blood, nasal and oral secre- Allergen extracts as CSPs are not subject to the tions, shed skin and cosmetics, other nonster- personnel, environmental, and storage require- ile materials) of critical sites (e.g., needles, ments for all CSP Microbial Contamination Risk opened ampuls, vial stoppers). Levels in this chapter only when all of the follow- 10. The label of each multiple-dose vial (MDV) ing criteria are met: of allergen extracts as CSPs lists the name of 1. The compounding process involves simple one specific patient and a BUD and storage transfer via sterile needles and syringes of temperature range that is assigned based on commercial sterile allergen products and ap- manufacturers recommendations or peer-re- propriate sterile added substances (e.g., glyc- viewed publications. erin, phenol in sodium chloride injection). 11. Single-dose allergen extracts as CSPs shall 2. All allergen extracts as CSPs shall contain ap- not be stored for subsequent additional use. propriate substances in effective concentra- Personnel who compound allergen extracts as tions to prevent the growth of microorgan- CSPs must be aware of greater potential risk of isms. Nonpreserved allergen extracts shall microbial and foreign material contamination comply with the appropriate CSP risk level when allergen extracts as CSPs are compounded in requirements in the chapter. compliance with the foregoing criteria instead of 3. Before beginning compounding activities, the more rigorous standards in this chapter for CSP personnel perform a thorough hand-cleansing Microbial Contamination Risk Levels. Although procedure by removing debris from under fin- contaminated allergen extracts as CSPs can pose gernails using a nail cleaner under running health risks to patients when they are injected in- warm water followed by vigorous hand and tradermally or subcutaneously, these risks are sub- arm washing to the elbows for at least 30 sec- stantially greater if the extract is inadvertently in- onds with either nonantimicrobial or antimi- jected intravenously. crobial soap and water. 4. Compounding personnel don hair covers, fa- VERIFICATION OF COMPOUNDING cial hair covers, gowns, and face masks. ACCURACY AND STERILITY 5. Compounding personnel perform antiseptic hand cleansing with an alcohol-based surgical The compounding procedures and sterilization hand scrub with persistent activity. methods for CSPs correspond to correctly de- 6. Compounding personnel don powder-free signed and verified written documentation in the sterile gloves that are compatible with sterile compounding facility. Verification requires 70% isopropyl alcohol (IPA) before begin- planned testing, monitoring, and documentation to ning compounding manipulations. demonstrate adherence to environmental quality 7. Compounding personnel disinfect their gloves requirements, personnel practices, and procedures intermittently with sterile 70% IPA when pre- critical to achieving and maintaining sterility, ac- paring multiple allergen extracts as CSPs. curacy, and purity of finished CSPs. For example, 8. Ampul necks and vial stoppers on packages of sterility testing (see Test for Sterility of the Prod- manufactured sterile ingredients are disin- uct To Be Examined under Sterility Tests 71) fected by careful wiping with sterile 70% IPA may be applied to specimens of low- and medium- swabs to ensure that the critical sites are wet risk level CSPs, and standard self-contained bio- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 17 logical indicators (BI) shall be added to nondis- Sterility Assurance of Compendial Articles 1211) pensable specimens of high-risk level CSPs before both sterilizes and maintains the strength, purity, terminal sterilization for subsequent evaluation to quality, and packaging integrity of CSPs. The se- determine whether the sterilization cycle was ade- lected sterilization process is obtained from experi- quate (see Biological Indicators for Sterilization ence and appropriate information sources (e.g., see 1035). Packaged and labeled CSPs shall be visu- Sterilization and Sterility Assurance of Com- ally inspected for physical integrity and expected pendial Articles 1211)and, preferably, verified appearance, including final fill amount. The accu- wherever possibleto achieve sterility in the par- racy of identities, concentrations, amounts, and pu- ticular CSPs. General guidelines for matching rities of ingredients in CSPs shall be confirmed by CSPs and components to appropriate sterilization reviewing labels on packages, observing and docu- methods include the following: menting correct measurements with approved and 1. CSPs have been ascertained to remain physi- correctly standardized devices, and reviewing in- cally and chemically stable when subjected to formation in labeling and certificates of analysis the selected sterilization method. provided by suppliers. When the correct identity, 2. Glass and metal devices may be covered purity, strength, and sterility of ingredients and tightly with aluminum foil, then exposed to components of CSPs cannot be confirmed (in dry heat in an oven at a mean temperature of cases of, for example, unlabeled syringes, opened 250 for 30 minutes to achieve sterility and ampuls, punctured stoppers of vials and bags, con- depyrogenation (see Dry-Heat Sterilization tainers of ingredients with incomplete labeling), under Sterilization and Sterility Assurance of such ingredients and components shall be dis- Compendial Articles 1211 and Bacterial En- carded immediately. dotoxins Test 85). Such items are either used Some individual ingredients, such as bulk drug immediately or stored until use in an environ- substances, are not labeled with expiration dates ment suitable for compounding Low-Risk when they are stable indefinitely in their commer- Level CSPs and Medium-Risk Level CSPs. cial packages under their labeled storage condi- 3. Personnel ascertain from appropriate informa- tions. However, despite retaining full chemical sta- tion sources that the sterile microporous bility, such ingredients may gain or lose moisture membrane filter used to sterilize CSP solu- during storage and use. Changes in moisture con- tions, during either compounding or adminis- tent may require testing (see Loss on Drying 731) tration, is chemically and physically compati- to determine the correct amount to weigh for accu- ble with the CSP. rate content of active chemical moieties in CSPs (see Pharmaceutical Calculations in Prescription STERILIZATION OF HIGH-RISK LEVEL CSPs BY Compounding 1160). FILTRATION Although not required, a quantitative stability-in- Commercially available sterile filters shall be ap- dicating chemical assay is recommended to ensure proved for human-use applications in sterilizing compounding accuracy of CSPs, especially those pharmaceutical fluids. Sterile filters used to steril- that contain drug ingredients with a narrow thera- ize CSPs shall be pyrogen free and have a nominal peutic plasma concentration range. pore size of 0.2 or 0.22 m. They shall be certified by the manufacturer to retain at least 10 7 microor- Sterilization Methods ganisms of a strain of Brevundimonas (Pseudomo- The licensed healthcare professionals who super- nas) diminuta on each square centimeter of up- vise compounding shall be responsible for deter- stream filter surface area under conditions similar mining that the selected sterilization method (see to those in which the CSPs will be sterilized (see Methods of Sterilization under Sterilization and High-Risk Conditions in High-Risk Level CSPs). Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 18 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin The compounding supervisor shall ensure, di- quired for the material to reach 121 before the rectly or from appropriate documentation, that the sterilization exposure duration is timed. filters are chemically and physically stable at the Not directly exposing items to pressurized steam pressure and temperature conditions to be used, may result in survival of microbial organisms and that they have enough capacity to filter the re- spores. Before their sterilization, plastic, glass, and quired volumes, and that they will achieve sterility metal devices are tightly wrapped in low-particle- and maintain prefiltration pharmaceutical quality, shedding paper or fabrics or sealed in envelopes including strength of ingredients of the specific that prevent poststerilization microbial penetration. CSP. The filter dimensions and liquid material to Immediately before filling ampuls and vials that be sterile-filtered shall permit the sterilization pro- will be steam sterilized, solutions are passed cess to be completed rapidly, without the replace- through a filter having a nominal pore size not ment of the filter during the process. When CSPs larger than 1.2 m for removal of particulate mat- are known to contain excessive particulate matter, ter. Sealed containers shall be able to generate a prefilter of larger nominal pore size membrane is steam internally; thus, stoppered and crimped placed upstream from the sterilizing filter to re- empty vials shall contain a small amount of mois- move gross particulate contaminants in order to ture to generate steam. maximize the efficiency of the sterilizing filter. The description of steam sterilization conditions and duration for specific CSPs shall be included in Filter units used to sterilize CSPs shall also be written documentation in the compounding facil- subjected to manufacturers recommended integ- ity. The effectiveness of steam sterilization shall rity test, such as the bubble point test. be verified using appropriate BIs of Bacillus Compounding personnel shall ascertain that se- stearothermophilus (see Biological Indicators lected filters will achieve sterilization of the partic- 1035) and other confirmation methods such as ular CSPs being sterilized. Large deviations from temperature-sensing devices (see Sterilization and usual or expected chemical and physical properties Sterility Assurance of Compendial Articles 1211 of CSPs (e.g., water-miscible alcohols) may cause and Sterility Tests 71). undetectable damage to filter integrity and shrink- age of microorganisms to sizes smaller than filter STERILIZATION OF HIGH-RISK LEVEL CSPs BY DRY nominal pore size. HEAT Dry heat sterilization is usually done as a batch STERILIZATION OF HIGH-RISK LEVEL CSPs BY process in an oven designed for sterilization. STEAM Heated filtered air shall be evenly distributed The process of thermal sterilization employing throughout the chamber by a blower device. The saturated steam under pressure, or autoclaving, is oven should be equipped with a system for con- the preferred method to terminally sterilize aque- trolling temperature and exposure period. Steriliza- ous preparations that have been verified to main- tion by dry heat requires higher temperatures and tain their full chemical and physical stability under longer exposure times than does sterilization by the conditions employed (see Steam Sterilization steam. Dry heat shall be used only for those mate- under Sterilization and Sterility Assurance of Com- rials that cannot be sterilized by steam, when ei- pendial Articles 1211). To achieve sterility, all ther the moisture would damage the material or the materials are to be exposed to steam at 121 under material is impermeable. During sterilization, suf- a pressure of about 1 atmosphere or 15 psi for the ficient space shall be left between materials to al- duration verified by testing to achieve sterility of low for good circulation of the hot air. The de- the items, which is usually 20 to 60 minutes for scription of dry heat sterilization conditions and CSPs. An allowance shall be made for the time re- duration for specific CSPs shall be included in Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 19 written documentation in the compounding facil- Exposure of Critical Sites ity. The effectiveness of dry heat sterilization shall Maintaining the sterility and cleanliness (i.e., be verified using appropriate BIs of Bacillus sub- freedom from sterile foreign materials) of critical tilis (see Biological Indicators 1035) and other sites is a primary safeguard for CSPs. Critical sites confirmation methods such as temperature-sensing are locations that include any component or fluid devices (see Sterilization and Sterility Assurance pathway surfaces (e.g., vial septa, injection ports, of Compendial Articles 1211 and Sterility Tests beakers) or openings (e.g., opened ampuls, needle 71). [NOTEDry heat sterilization may be per- hubs) exposed and at risk of direct contact with air formed at a lower temperature than may be effec- (e.g., ambient room or HEPA filtered), moisture tive for depyrogenation]. (e.g., oral and mucosal secretions), or touch con- tamination. The risk of, or potential for, critical Depyrogenation by Dry Heat sites to be contaminated with microorganisms and Dry heat depyrogenation shall be used to render foreign matter increases with increasing exposed glassware or containers such as vials free from py- area of the critical sites, the density or concentra- rogens as well as viable microbes. A typical cycle tion of contaminants, and exposure duration to would be 30 minutes at 250. The description of worse than ISO Class 5 (see Table 1) air. Exam- the dry heat depyrogenation cycle and duration for ples include an opened ampul or vial stopper on a specific load items shall be included in written 10-mL or larger vial or an injection port on a pack- documentation in the compounding facility. The age of intravenous solution having an area larger effectiveness of the dry heat depyrogenation cycle than the point of a needle or the tip of a syringe. shall be verified using endotoxin challenge vials The nature of a critical site also affects the risk (ECVs). The bacterial endotoxin test should be of contamination. The relatively rough, permeable performed on the ECVs to verify that the cycle is surface of an elastomeric closure retains microor- capable of achieving a 3-log reduction in endo- ganisms and other contaminants after swabbing toxin (see Sterilization and Sterility Assurance of with a sterile 70% IPA pad more readily than does Compendial Articles 1211 and Bacterial Endo- the smoother glass surface of the neck of an am- toxins Test 85). pul. Therefore, the surface disinfection can be ex- pected to be more effective for an ampul. ENVIRONMENTAL QUALITY AND Protection of critical sites by precluding physical CONTROL contact and airborne contamination shall be given the highest priority in sterile compounding prac- Achieving and maintaining sterility and overall tice. Airborne contaminants, especially those gen- freedom from contamination of a CSP is depend- erated by sterile compounding personnel, are much ent on the quality status of the components incor- more likely to reach critical sites than are contami- porated, the process utilized, personnel perform- nants that are adhering to the floor or other sur- ance, and the environmental conditions under faces below the work level. Furthermore, large and which the process is performed. The standards re- high-density particles that are generated and intro- quired for the environmental conditions depend on duced by compounding manipulations and person- the amount of exposure of the CSP to the immedi- nel have the potential to settle on critical sites even ate environment anticipated during processing. when those critical sites are exposed within ISO The quality and control of environmental condi- Class 5 (see Table 1) air. tions for each risk level of operation are explained in this section. In addition, operations using non- sterile components require the use of a method of preparation designed to produce a sterile preparation. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 20 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin ISO Class 5 Air Sources, Buffer Areas, and categorized as low-, medium-, and high-risk level. Ante-Areas The quality of the environmental air increases with movement from the outer boundary to the direct The most common sources of ISO Class 5 (see compounding area (DCA). Placement of devices in Table 1) air quality for exposure of critical sites ante-areas and buffer areas is dictated by their ef- are horizontal and vertical LAFWs, CAIs, and fect on the designated environmental quality of at- CACIs. A clean room (see Microbiological Evalu- mospheres and surfaces, which shall be verified by ation of Clean Rooms and Other Controlled Envi- monitoring (see Viable and Nonviable Environ- ronments 1116) is a compounding environment mental Sampling (ES) Testing). It is the responsi- that is supplied with HEPA or HEPA-filtered air bility of each compounding facility to ensure that that meets ISO Class 7 (see Table 1), the access to each source of ISO Class 5 (see Table 1) environ- which is limited to personnel trained and author- ment for exposure of critical sites and ized to perform sterile compounding and facility sterilization by filtration is properly located, oper- cleaning. A buffer area is an area that provides at ated, maintained, monitored, and verified. least ISO Class 7 (see Table 1) air quality. Figure 1 is a conceptual representation of the placement of an ISO Class 5 (see Table 1) PEC in a segregated compounding area used for low-risk level CSPs with 12-hour or less BUD. This plan depicts the most critical operation area located within the PEC in a designated area (see definition of Segregated Compounding Area) separated from activities not essential to the preparation of CSPs. Placement of devices (e.g., computers, printers) and objects (e.g., carts, cabinets) that are not es- sential to compounding in the segregated area should be restricted or limited, depending on their Figure 2. Conceptual representation of the arrangement of a facil- ity for preparation of CSPs categorized as low-, medium-, and effect on air quality in the ISO Class 5 (see Table high-risk level. 1) PEC. Placement of devices (e.g., computers, printers) and objects (e.g., carts, cabinets) that are not es- sential to compounding in buffer areas is dictated by their effect on the required environmental qual- ity of air atmospheres and surfaces, which shall be verified by monitoring (see Viable and Nonviable Environmental Sampling (ES) Testing). It is the re- sponsibility of each compounding facility to en- sure that each source of ISO Class 5 (see Table 1) environment for exposure of critical sites and ster- ilization by filtration is properly located, operated, maintained, monitored, and verified. Figure 1. Conceptual representation of the placement of an ISO Class 5 PEC in a segregated compounding area used for low-risk Facility Design and Environmental Controls level CSPs with 12-hour or less BUD. Figure 2 is a conceptual representation of the ar- Compounding facilities are physically designed rangement of a facility for preparation of CSPs and environmentally controlled to minimize air- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 21 borne contamination from contacting critical sites. compounding activities utilized during the prepa- These facilities shall also provide a comfortable ration of the CSPs. The CSP work environment is and well-lighted working environment, which typi- designed to have the cleanest work surfaces (PEC) cally includes a temperature of 20 or cooler, to located in a buffer area. The buffer area shall maintain comfortable conditions for compounding maintain at least ISO Class 7 (see Table 1) condi- personnel to perform flawlessly when attired in the tions for 0.5-m and larger particles under dy- required aseptic compounding garb. PECs typi- namic operating conditions. The room shall be cally include, but are not limited to, LAFWs, segregated from surrounding, unclassified spaces BSCs, CAIs, and CACIs, which provide an ISO to reduce the risk of contaminants being blown, Class 5 (see Table 1) environment for the exposure dragged, or otherwise introduced into the filtered of critical sites. PECs shall maintain ISO Class 5 unidirectional airflow environment, and this segre- (seeTable 1) or better conditions for 0.5-m parti- gation shall be continuously monitored. For rooms cles (dynamic operating conditions) while com- providing a physical separation through the use of pounding CSPs. Secondary engineering controls walls, doors, and pass-throughs, a minimum differ- such as buffer areas and ante-areas generally serve ential positive pressure of 0.02- to 0.05-inch water as a core for the location of the PEC. Buffer areas column is required. For buffer areas not physically are designed to maintain at least ISO Class 7 (see separated from the ante-areas, the principle of dis- Table 1) conditions for 0.5-m particles under dy- placement airflow shall be employed. This concept namic conditions and ISO Class 8 (see Table 1) utilizes a low pressure differential, high airflow conditions for 0.5-m and larger particles under principle. Using displacement airflow typically re- dynamic conditions for the ante-areas. Airborne quires an air velocity of 40 ft per minute or more contamination control is achieved in the PEC from the buffer area across the line of demarcation through the use of HEPA filters. The airflow in the into the ante-area. PEC shall be unidirectional (laminar flow), and be- The displacement concept shall not be used for cause of the particle collection efficiency of the fil- high-risk compounding. 6 The PEC shall be placed ter, the first air at the face of the filter is, for the within a buffer area in such a manner as to avoid purposes of aseptic compounding, free from air- conditions that could adversely affect their opera- borne particulate contamination. HEPA-filtered air tion. For example, strong air currents from opened shall be supplied in critical areas (ISO Class 5, see doors, personnel traffic, or air streams from the Table 1) at a velocity sufficient to sweep particles HVAC systems can disrupt the unidirectional air- away from the compounding area and maintain flow in open-faced workbenches. The operators unidirectional airflow during operations. Proper may also create disruptions in airflow by their own design and control prevents turbulence and stag- movements and by the placement of objects onto nant air in the critical area. In situ air pattern anal- the work surface. The PEC shall be placed out of ysis via smoke studies shall be conducted at the the traffic flow and in a manner to avoid disruption critical area to demonstrate unidirectional airflow from the HVAC system and room cross-drafts. and sweeping action over and away from the prod- Room air exchanges are typically expressed as uct under dynamic conditions. ACPHs. Adequate HEPA-filtered airflow supplied The principles of HEPA-filtered unidirectional to the buffer area and ante-area is required to airflow in the work environment shall be under- maintain cleanliness classification during opera- stood and practiced in the compounding process in tional activity through the number of ACPHs. Fac- order to achieve the desired environmental condi- tors that should be considered when determining tions. Policies and procedures for maintaining and air-change requirements include number of per- working within the PEC area shall be written and 6 ISO 14644-4: 2001 Cleanrooms and associated controlled envi- followed. The policies and procedures will be de- ronmentsDesign, construction, and start-up, Case Postale 56, termined by the scope and risk levels of the aseptic CH-1211 Geneve 20, Switzerland, tel. +41 22 749 01 11. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 22 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin sonnel working in the room and compounding mulate. The surfaces shall be resistant to damage processes that generate particulates, as well as by disinfectant agents. J unctures of ceilings to temperature effects. An ISO Class 7 (see Table 1) walls shall be coved or caulked to avoid cracks buffer area and ante-area supplied with HEPA-fil- and crevices where dirt can accumulate. If ceilings tered air shall receive an ACPH of not less than consist of inlaid panels, the panels shall be impreg- 30. The PEC is a good augmentation to generating nated with a polymer to render them impervious air changes in the air supply of an area but cannot and hydrophobic, and they shall be caulked around be the sole source of HEPA-filtered air. If the area each perimeter to seal them to the support frame. has an ISO Class 5 (see Table 1) recirculating de- Walls may be constructed of flexible material vice, a minimum of 15 ACPHs through the area (e.g., heavy gauge polymer), panels locked to- supply HEPA filters is adequate, providing the gether and sealed, or of epoxy-coated gypsum combined ACPH is not less than 30. More air board. Preferably, floors are overlaid with wide changes may be required, depending on the num- sheet vinyl flooring with heat-welded seams and ber of personnel and processes. HEPA-filtered coving to the sidewall. Dust-collecting overhangs, supply air shall be introduced at the ceiling, and such as ceiling utility pipes, and ledges, such as returns should be mounted low on the wall, creat- windowsills, should be avoided. The exterior lens ing a general top-down dilution of area air with surface of ceiling lighting fixtures should be HEPA-filtered make-up air. Ceiling-mounted re- smooth, mounted flush, and sealed. Any other pen- turns are not recommended. All HEPA filters etrations through the ceiling or walls shall be should be efficiency tested using the most pene- sealed. The buffer area shall not contain sources of trating particle size and should be leak tested at the water (sinks) or floor drains. Work surfaces shall factory and then leak tested again in situ after in- be constructed of smooth, impervious materials, stallation. 7 such as stainless steel or molded plastic, so that Activities and tasks carried out within the buffer they are easily cleaned and disinfected. Carts area shall be limited to only those necessary when should be of stainless steel wire, nonporous working within a controlled environment. Only the plastic, or sheet metal construction with good qual- furniture, equipment, supplies, and other material ity, cleanable casters to promote mobility. Storage required for the compounding activities to be per- shelving, counters, and cabinets shall be smooth, formed shall be brought into the area, and they impervious, free from cracks and crevices, non- shall be nonpermeable, nonshedding, cleanable, shedding, cleanable, and disinfectable; their num- and resistant to disinfectants. Whenever such items ber, design, and manner of installation shall pro- are brought into the area, they shall first be cleaned mote effective cleaning and disinfection. and disinfected. Whenever possible, equipment and other items used in the buffer area shall not be Placement of Primary Engineering Controls taken out of the area except for calibration, servic- PECs (LAFWs, BSCs, CAIs, and CACIs) shall ing, or other activities associated with the proper be located within a restricted access ISO Class 7 maintenance of the item. (see Table 1) buffer area (see Figure 1), with the The surfaces of ceilings, walls, floors, fixtures, following CAI/CACI exceptions below: shelving, counters, and cabinets in the buffer area Only authorized personnel and materials re- shall be smooth, impervious, free from cracks and quired for compounding and cleaning shall be crevices, and nonshedding, thereby promoting permitted in the buffer area. cleanability and minimizing spaces in which mi- croorganisms and other contaminants may accu- Presterilization procedures for high-risk level CSPs, such as weighing and mixing, shall be 7 By definition (IEST RP CC 001.4), HEPA filters are a minimum of 99.97% efficient when tested using 0.3-m thermally generated completed in no worse than an ISO Class 8 particles and a photometer or rated at their most penetrating particle size using a particle counter. (seeTable 1) environment. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 23 PECs shall be located out of traffic patterns Viable and Nonviable Environmental and away from room air currents that could Sampling (ES) Testing disrupt the intended airflow patterns. The ES program should provide information to CAIs and CACIs shall be placed in an ISO Class staff and leadership to demonstrate that the PEC is 7 (see Table 1) buffer area unless they meet all of maintaining an environment within the compound- the following conditions: ing area that consistently ensures acceptably low The isolator shall provide isolation from the viable and nonviable particle levels. The com- room and maintain ISO Class 5 (see Table 1) pounding area includes the ISO Class 5 (see Table during dynamic operating conditions, includ- 1) PEC (LAFWs, BSCs, CAIs, and CACIs), buffer ing transferring ingredients, components, and areas, ante-areas, and segregated compounding devices into and out of the isolator and during areas. preparation of CSPs. Environmental sampling shall occur as part a Particle counts sampled approximately 6 to 12 comprehensive quality management program and inches upstream of the critical exposure site shall occur minimally under any of the following shall maintain ISO Class 5 (see Table 1) lev- conditions: els during compounding operations. as part of the commissioning and certification Not more than 3520 particles (0.5 m and of new facilities and equipment; larger) per m 3 shall be counted during ma- following any servicing of facilities and terial transfer, with the particle counter probe equipment; located as near to the transfer door as possible as part of the re-certification of facilities and without obstructing the transfer. 8 equipment (i.e., every 6 months); It is incumbent on the compounding personnel to in response to identified problems with end obtain documentation from the manufacturer that products or staff technique; or the CAI/CACI will meet this standard when lo- in response to issues with CSPs, observed cated in environments where the background parti- compounding personnel work practices, or cle counts exceed ISO Class 8 (see Table 1) for patient-related infections (where the CSP is 0.5-m and larger particles. When isolators are being considered as a potential source of the used for sterile compounding, the recovery time to infection). achieve ISO Class 5 (see Table 1) air quality shall be documented and internal procedures developed ENVIRONMENTAL NONVIABLE PARTICLE TESTING to ensure that adequate recovery time is allowed PROGRAM after material transfer before and during com- A program to sample nonviable airborne parti- pounding operations. cles differs from that for viable particles in that it If the PEC is a CAI or CACI that does not meet is intended to directly measure the performance of the requirements above or is a LAFW or BSC that the engineering controls used to create the various cannot be located within an ISO Class 7 (see Table levels of air cleanliness, for example, ISO Class 5, 1) buffer area, then only low-risk level nonhazard- 7, or 8 (see Table 1). ous and radiopharmaceutical CSPs pursuant to a Engineering Control Performance Verifi- physician order for a specific patient may be pre- cationPECs (LAFWs, BSCs, CAIs, and CACIs) pared, and administration of the CSP shall com- and secondary engineering controls (buffer and mence within 12 hours of preparation or as recom- ante-areas) are essential components of the overall mended in the manufacturers package insert, contamination control strategy for aseptic com- whichever is less. pounding. As such, it is imperative that they per- 8 Sample procedures are detailed in CETA Applications Guide CAG-002-2006section 2.09. form as designed and that the resulting levels of Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 24 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin contamination be within acceptable limits. Certifi- than 5 Pa (0.02 inch water column). In facilities cation procedures such as those outlined in Certi- where low- and medium-risk level CSPs are pre- fication Guide for Sterile Compounding Facilities pared, differential airflow shall maintain a mini- (CAG-003-2006) 9 shall be performed by a quali- mum velocity of 0.2 meters per second (40 feet per fied individual no less than every 6 months and minute) between buffer area and ante-area. whenever the device or room is relocated or al- tered or major service to the facility is performed. ENVIRONMENTAL VIABLE AIRBORNE PARTICLE Total Particle CountsCertification that each TESTING PROGRAM ISO classified area, for example, ISO Class 5, 7, The risk of contaminating a CSP prepared under and 8 (see Table 1), is within established guide- low-risk level and medium-risk level conditions is lines shall be performed no less than every 6 highly dependent on proper hand hygiene and months and whenever the LAFW, BSC, CAI, or garbing practices, compounding personnel aseptic CACI is relocated or the physical structure of the technique, and the presence of surface contamina- buffer area or ante-area has been altered. Testing tion, assuming that all work is performed in a cer- shall be performed by qualified operators using tified and properly functioning ISO Class 5 (see current, state-of-the-art electronic equipment with Table 1) PEC and secondary engineering controls, results of the following: ISO Class 7 (see Table 1) buffer area, and ISO ISO Class 5: not more than 3520 particles 0.5 Class 8 (see Table 1) ante-area. High-risk level m and larger size per cubic meter of air for CSPs pose the greatest threat to patients because any LAFW, BSC, CAI, and CACI; compounding personnel are tasked with the re- ISO Class 7: not more than 352,000 particles quirement of processing nonsterile components of 0.5 m size and larger per cubic meter of and devices in order to achieve sterility. air for any buffer area; A sampling program in conjunction with an ob- ISO Class 8: not more than 3,520,000 parti- servational audit is designed to evaluate the com- cles or 0.5 m size and larger per cubic meter petency of compounding personnel work practices, of air for any ante-area. allowing for the implementation of corrective ac- All certification records shall be maintained and tions on an ongoing basis (see Personnel Training reviewed by supervising personnel or other desig- and Competency Evaluation of Garbing, Aseptic nated employees to ensure that the controlled envi- Work Practices and Cleaning/Disinfection ronments comply with the proper air cleanliness, Procedures). room pressures, and ACPHs. Sampling PlanAn appropriate environmental sampling plan shall be developed for airborne via- PRESSURE DIFFERENTIAL MONITORING ble particles based on a risk assessment of com- pounding activities performed. A pressure gauge or velocity meter shall be in- Selected sampling sites shall include locations stalled to monitor the pressure differential or air- within each ISO Class 5 (see Table 1) environment flow between the buffer area and the ante-area and and in the ISO Class 7 and 8 (see Table 1) areas between the ante-area and the general environment and in the segregated compounding areas at great- outside the compounding area. The results shall be est risk of contamination (e.g., work areas near the reviewed and documented on a log at least every ISO Class 5 [see Table 1] environment, counters work shift (minimum frequency shall be at least near doors, pass-through boxes). The plan shall in- daily) or by a continuous recording device. The clude sample location, method of collection, fre- pressure between the ISO Class 7 (see Table 1) quency of sampling, volume of air sampled, and and the general pharmacy area shall not be less time of day as related to activity in the compound- 9 Controlled Environment Testing Association, 1500 Sunday Drive, Ste. 102, Raleigh, NC 27607; www.CETAinternational.org. ing area and action levels. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 25 Review of the data generated during a sampling should be given to the overall effect the chosen event may detect elevated amounts of airborne mi- sampling method will have on the unidirectional crobial bioburden; such changes may be indicative airflow within a compounding environment. of adverse changes within the environment. It is For low-risk level CSPs with 12-hour or less recommended that compounding personnel refer to BUD prepared in a PEC (LAFWs, BSCs, CAIs) Microbiological Evaluation of Clean Rooms and that maintains an ISO Class 5 (see Table 1), air Other Controlled Environments 1116 and the sampling shall be performed at locations inside the CDCs Guidelines for Environmental Infection ISO Class 5 (see Table 1) environment and other Control in Healthcare Facilities, 2003 for more areas that are in close proximity to the ISO Class 5 information. (seeTable 1) environment during the certification Growth MediumA general microbiological of the PEC. growth medium such as SoybeanCasein Digest Air Sampling DevicesThere are a number of Medium shall be used to support the growth of manufacturers of electronic air sampling equip- bacteria. Malt extract agar or some other media ment. It is important that personnel refer to the that support the growth of fungi shall be used in manufacturers recommended procedures when us- high-risk level compounding environments. Media ing the equipment to perform volumetric air sam- used for surface sampling must be supplemented pling procedures. The instructions in the manufac- with additives to neutralize the effects of disinfect- turers users manual for verification and use of ing agents (e.g., TSA with lecithin and polysorbate electric air samplers that actively collect volumes 80). of air for evaluation must be followed. A sufficient Viable Air SamplingEvaluation of airborne volume of air (400 to 1000 liters) shall be tested at microorganisms using volumetric collection meth- each location in order to maximize sensitivity. The ods in the controlled air environments (LAFWs, volumetric air sampling devices need to be serv- CAIs, clean room or buffer areas, and ante-areas) iced and calibrated as recommended by the shall be performed by properly trained individuals manufacturer. for all compounding risk levels. It is recommended that compounding personnel Impaction shall be the preferred method of volu- also refer to Methodology and Instrumentation for metric air sampling. Use of settling plates for qual- Quantitation of Viable Airborne Microorganisms itative air sampling may not be able to determine under Microbiological Evaluation of Clean Rooms adequately the quality of air in the controlled envi- and Other Controlled Environments 1116, which ronment. The settling of particles by gravity onto provides more information on the use of volu- culture plates depends on the particle size and may metric air samplers and volume of air that should be influenced by air movement. Consequently, the be sampled to detect environmental bioburden number of colony-forming units (cfu) on a settling excursions. plate may not always relate to the concentrations of viable particles in the sampled environment. Air Sampling Frequency and ProcessAir For low-, medium-, and high-risk level com- sampling shall be performed at least semiannually pounding, air sampling shall be performed at loca- (i.e., every 6 months) as part of the re-certification tions that are prone to contamination during com- of facilities and equipment. If compounding occurs pounding activities and during other activities such in multiple locations within an institution (e.g., as staging, labeling, gowning, and cleaning. Loca- main pharmacy, satellites), environmental sam- tions shall include zones of air backwash turbu- pling is required for each individual compounding lence within LAFW and other areas where air area. A sufficient volume of air shall be sampled backwash turbulence may enter the compounding and the manufacturers guidelines for use of the area (doorways, in and around ISO Class 5 [see electronic air sampling equipment followed. Any Table 1] PEC and environments). Consideration facility construction or equipment servicing may Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 26 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin require that air sampling be performed during rective actions will be dictated by the identifica- these events. tion of microorganisms recovered (at least the Incubation PeriodAt the end of the desig- genus level) by an appropriate credentialed labora- nated sampling or exposure period for air sampling tory of any microbial bioburden captured as a cfu activities, the microbial growth media plates are using an impaction air sampler. Highly pathogenic recovered and their covers secured (e.g., taped), microorganisms (e.g., Gram-negative rods, coagu- and they are inverted and incubated at a tempera- lase positive staphylococcus, molds and yeasts) ture and for a time period conducive to multiplica- can be potentially fatal to patients receiving CSPs tion of microorganisms. TSA should be incubated and must be immediately remedied, regardless of at 30 to 35 for 48 to 72 hours. Malt extract agar cfu count, with the assistance of a competent mi- or other suitable fungal media should be incubated crobiologist, infection control professional, or in- at 26 to 30 for 5 to 7 days. The number of dis- dustrial hygienist. crete colonies of microorganisms are counted and Table 2. Recommended Action Levels for reported as cfu and documented on an environ- Microbial Contamination * mental sampling form. Counts from air sampling
(cfu per cubic meter [1000 liters] of air per
need to be transformed into cfu per cubic meter of plate) air and evaluated for adverse trends. Classification Air Sample Action Levels, Documentation, and Data EvaluationThe value of viable microbial sam- ISO Class 5 >1 pling of the air in the compounding environment is ISO Class 7 >10 realized when the data are used to identify and cor- ISO Class 8 or worse >100 rect an unacceptable situation. Sampling data shall * Guidance for IndustrySterile Drug Products Produced by Asep- tic ProcessingCurrent Good Manufacturing PracticeUS HHS, be collected and reviewed on a periodic basis as a FDA September 2004. means of evaluating the overall control of the com- pounding environment. If an activity consistently shows elevated levels of microbial growth, compe- Additional Personnel Requirements tent microbiology personnel shall be consulted. Any cfu count that exceeds its respective action Food, drinks, and materials exposed in patient level (see Table 2) should prompt a re-evaluation care and treatment areas shall not enter ante-areas, of the adequacy of personnel work practices, buffer areas, or segregated compounding areas cleaning procedures, operational procedures, and where components and ingredients of CSPs are air filtration efficiency within the aseptic com- present. When compounding activities require the pounding location. An investigation into the manipulation of a patients blood-derived or other source of the contamination shall be conducted. biological material (e.g., radiolabeling a patients Sources could include HVAC systems, damaged or donors white blood cells), the manipulations HEPA filters, and changes in personnel garbing or shall be clearly separated from routine material- work practices. The source of the problem shall be handling procedures and equipment used in CSP eliminated, the affected area cleaned, and preparation activities, and they shall be controlled resampling performed. by specific SOPs in order to avoid any cross-con- Counts of cfu are to be used as an approximate tamination. Packaged compounding supplies and measure of the environmental microbial bi- components, such as needles, syringes, tubing sets, oburden. Action levels are determined on the basis and small- and large-volume parenterals, should be of cfu data gathered at each sampling location and uncartoned and wiped down with a disinfectant trended over time. The numbers in Table 2 should that does not leave a residue (e.g., sterile 70% be used only as guidelines. Regardless of the num- IPA), when possible in an ante-area of ISO Class 8 ber of cfu identified in the pharmacy, further cor- (seeTable 1) air quality, before being passed into Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 27 the buffer areas. Personnel hand hygiene and garb- be effective in the presence of light to moderate ing procedures are also performed in the ante-area, soiling without a pre-cleaning step. which may contain a sink that enables hands-free Surfaces in LAFWs, BSCs, CAIs, and CACIs, use with a closed system of soap dispensing to which are intimate to the exposure of critical sites, minimize the risk of extrinsic contamination. require disinfecting more frequently than do There shall be some demarcation designation that housekeeping surfaces such as walls and ceilings. separates the ante-area from the buffer area. Ade- Disinfecting sterile compounding areas shall occur quate provision for performing antiseptic hand on a regular basis at the intervals noted in Table 3 cleansing usng an alcohol-based surgical hand when spills occur, when the surfaces are visibly scrub with persistent activity followed by the don- soiled, and when microbial contamination is ning of sterile gloves should be provided after en- known to have been or is suspected of having been try into the buffer area. introduced into the compounding areas. When the surface to be disinfected has heavy soiling, a cleaning step is recommended prior to Cleaning and Disinfecting the Compounding the application of the disinfectant. Trained com- Area pounding personnel are responsible for develop- Environmental contact is a major source of mi- ing, implementing, and practicing the procedures crobial contamination of CSPs. Consequently, for cleaning and disinfecting the DCAs written in scrupulous attention to cleaning and disinfecting the SOPs. Cleaning and disinfecting shall occur the sterile compounding areas is required to mini- before compounding is performed. Items shall be mize this as a source of CSP contamination. removed from all areas to be cleaned, and surfaces The cleaning and disinfecting practices and fre- shall be cleaned by removing loose material and quencies in this section apply to ISO Class 5 (see residue from spills; for example, water-soluble Table 1) compounding areas for exposure of criti- solid residues are removed with sterile water (for cal sites as well as buffer areas, ante-areas, and injection or irrigation) and low-shedding wipes. segregated compounding areas. Compounding per- This shall be followed by wiping with a residue- sonnel are responsible for ensuring that the fre- free disinfecting agent such as sterile 70% IPA, quency of cleaning is in accordance with the re- which is allowed to dry before compounding quirements stated in Table 3 and determining the begins. cleaning and disinfecting products to be used (see Cleaning and disinfecting surfaces in the Appendix II). Any organizational or institutional LAFWs, BSCs, CAIs, and CACIs are the most policies regarding disinfectant selection should be critical practices before the preparation of CSPs. considered by compounding personnel. All clean- Consequently, such surfaces shall be cleaned and ing and disinfecting practices and policies for the disinfected frequently, including at the beginning compounding of CSPs shall be included in written of each work shift, before each batch preparation SOPs and shall be followed by all compounding is started, every 30 minutes during continuous personnel. compounding periods of individual CSPs, when The selection and use of disinfectants in health- there are spills, and when surface contamination is care facilities is guided by several properties, such known or suspected from procedural breaches. as microbicidal activity, inactivation by organic Work surfaces in the ISO Class 7 (see Table 1) matter, residue, and shelf life (see Appendix II). In buffer areas and ISO Class 8 (see Table 1) ante- general, highly toxic disinfectants, such as glutar- areas as well as segregated compounding areas aldehyde, are not used on housekeeping surfaces shall be cleaned and disinfected at least daily, and (e.g., floors, countertops). Many disinfectants reg- dust and debris shall be removed when necessary istered by the EPA are one-step disinfectants. This from storage sites for compounding ingredients means that the disinfectant has been formulated to and supplies using a method that does not degrade Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 28 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin the ISO Class 7 or 8 (see Table 1) air quality (see posed of synthetic micro fibers, and dedicated to Disinfectants and Antiseptics 1072). use in the buffer or clean area, ante-area, and seg- regated compounding areas and shall not be re- Table 3. Minimum Frequency of Cleaning and moved from these areas except for disposal. Floor Disinfecting Compounding Areas mops may be used in both the buffer or clean area Site Minimum Frequency and ante-area, but only in that order. Ideally, all cleaning tools are discarded after one use by col- ISO Class 5 (see At the beginning of each lection in suitable plastic bags and removed with Table 1) Primary shift, before each batch, minimal agitation. If cleaning materials (e.g., Engineering not longer than 30 min- mops) are reused, procedures shall be developed Control (e.g., utes following the previ- (based on manufacturers recommendations) that LAFW, BSC, ous surface disinfection ensure that the effectiveness of the cleaning device CAI, CACI) when ongoing compound- is maintained and that repeated use does not add to ing activities are occur- the bioburden of the area being cleaned. ring, after spills, and when surface contamina- Supplies and equipment removed from shipping tion is known or cartons shall be wiped with a suitable disinfecting suspected agent (e.g., sterile 70% IPA) delivered from a Counters and easi- Daily spray bottle or other suitable delivery method. Af- ly cleanable ter the disinfectant is sprayed or wiped on a sur- work surfaces face to be disinfected, the disinfectant shall be al- Floors Daily lowed to dry, during which time the item shall not be used for compounding purposes. Walls Monthly Ceilings Monthly Wiping with small sterile 70% IPA swabs that Storage shelving Monthly are commercially available in individual foil- sealed packages (or a comparable method) is pre- Floors in the buffer or clean area, ante-area, and ferred for disinfecting entry points on bags and vi- segregated compounding area are cleaned by mop- als, allowing the IPA to dry before piercing stop- ping with a cleaning and disinfecting agent once pers with sterile needles and breaking necks of daily at a time when no aseptic operations are in ampuls. The surface of the sterile 70% IPA swabs progress. Mopping shall be performed by trained used for disinfecting entry points of sterile pack- personnel using approved agents and procedures ages and devices shall not contact any other object described in the written SOPs. It is incumbent on before contacting the surface of the entry point. compounding personnel to ensure that such clean- Sterile 70% IPA wetted gauze pads or other parti- ing is performed properly. In the buffer or clean cle-generating material shall not be used to disin- area, ante-area, and segregated compounding area, fect the sterile entry points of packages and walls, ceilings, and shelving shall be cleaned and devices. disinfected monthly. Cleaning and disinfecting When sterile supplies are received in sealed agents are to be used with careful consideration of pouches designed to keep them sterile until open- compatibilities, effectiveness, and inappropriate or ing, the sterile supplies may be removed from the toxic residues (see Appendix II). Their schedules covering pouches as the supplies are introduced of use and methods of application shall be in ac- into the ISO Class 5 (see Table 1) PEC (LAFW, cordance with written SOPs and followed by cus- BSC, CAI, CACI) without the need to disinfect the todial or compounding personnel. individual sterile supply items. No shipping or All cleaning materials, such as wipers, sponges, other external cartons may be taken into the buffer and mops, shall be nonshedding, preferably com- or clean area or segregated compounding area. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 29 Personnel Cleansing and Garbing ning of dedicated shoes or shoe covers, head and facial hair covers (e.g., beard covers in addition to The careful cleansing of hands and arms and the face masks), and face masks/eye shields. Eye correct donning of PPE by compounding personnel shields are optional unless working with irritants constitute the first major step in preventing micro- such as germicidal disinfecting agents or when bial contamination in CSPs. Personnel shall also preparing hazardous drugs. be thoroughly competent and highly motivated to After donning dedicated shoes or shoe covers, perform flawless aseptic manipulations with in- head and facial hair covers, and face masks, a hand gredients, devices, and components of CSPs. cleansing procedure shall be performed by remov- Squamous cells are normally shed from the human ing debris from underneath fingernails using a nail body at a rate of 10 6 or more per hour, and those cleaner under running warm water followed by skin particles are laden with microorganisms. 10,11 vigorous hand washing. Hands and forearms shall When individuals are experiencing rashes, sun- be washed to the elbows for at least 30 seconds burn, weeping sores, conjunctivitis, active respira- with soap (either nonantimicrobial or antimicro- tory infection, as well as when they wear cosmet- bial) and water while in the ante-area. The use of ics, they shed these particles at even higher rates. antimicrobial scrub brushes is not recommended Particles shed from compounding personnel pose because they can cause skin irritation and skin an increased risk of microbial contamination of damage. Hands and forearms to the elbows will be critical sites of CSPs. Therefore, compounding completely dried using either lint-free disposable personnel with such conditions as mentioned towels or an electronic hand dryer. After comple- above shall be excluded from working in ISO tion of hand washing, a nonshedding gown with Class 5 (see Table 1) and ISO Class 7 (see Table sleeves that fit snugly around the wrists and en- 1) compounding areas until their conditions are closed at the neck is donned. Gowns designated remedied. for buffer area use shall be worn, and preferably Before entering the buffer area or segregated they should be disposable. If reusable gowns are compounding area (see Low-Risk Level CSPs with worn, they should be laundered appropriately for 12-Hour or Less BUD), compounding personnel buffer area use. shall remove personal outer garments (e.g., ban- Once inside the buffer area or segregated com- dannas, coats, hats, jackets, scarves, sweaters, pounding area (see Low-Risk Level CSPs with 12- vests); all cosmetics, because they shed flakes and Hour or Less BUD), and prior to donning sterile particles; and all hand, wrist, and other visible jew- powder-free gloves, antiseptic hand cleansing shall elry or piercings (e.g., earrings, lip or eyebrow be performed using a waterless alcohol-based sur- piercings) that can interfere with the effectiveness gical hand scrub with persistent activity 12 follow- of PPE (e.g., fit of gloves and cuffs of sleeves). ing manufacturers recommendations. Hands are The wearing of artificial nails or extenders is pro- allowed to dry thoroughly before donning sterile hibited while working in the sterile compounding gloves. environment. Natural nails shall be kept neat and Sterile gloves shall be the last item donned be- trimmed. fore compounding begins. Gloves become contam- Personnel shall don the following PPE in an or- inated when they contact nonsterile surfaces dur- der that proceeds from those activities considered ing compounding activities. Disinfection of the dirtiest to those considered the cleanest. Garb- contaminated gloved hands may be accomplished ing activities considered the dirtiest include don- by wiping or rubbing sterile 70% IPA to all con- 10 Agalloco J , Akers J E. Aseptic Processing: A Vision of the Future. tact surface areas of the gloves and letting the Pharmaceutical Technology, 2005. Aseptic Processing supplement, s16. 12 Guideline for Hand Hygiene in Health care Settings, MMWR, 11 Eaton T. Microbial Risk Assessment for Aseptically Prepared October 25, 2002, vol. 51, No. RR-16 available on the Internet at Products. Am Pharm Rev. 2005; 8 (5, Sep/Oct): 4651. http://www.cdc.gov/handhygiene/. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 30 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin gloved hands dry thoroughly. Only use gloves that Personnel Training and Competency Evaluation of Garbing, Aseptic Work have been tested for compatibility with alcohol Practices, and Cleaning/Disinfection disinfection by the manufacturer. Routine applica- Procedures tion of sterile 70% IPA shall occur throughout the compounding process and whenever nonsterile Personnel who prepare CSPs shall be trained surfaces (e.g. vials, counter tops, chairs, carts) are conscientiously and skillfully by expert personnel touched. Gloves on hands shall also be routinely and through multimedia instructional sources and inspected for holes, punctures, or tears and re- professional publications in the theoretical princi- placed immediately if such are detected. Antiseptic ples and practical skills of garbing procedures, hand cleansing shall be performed as indicated aseptic work practices, achieving and maintaining above. Compounding personnel shall be trained ISO Class 5 (see Table 1) environmental condi- and evaluated in the avoidance of touching critical tions, and cleaning and disinfection procedures. sites. This training shall be completed and documented before any compounding personnel begin to pre- When compounding personnel exit the com- pare CSPs. Compounding personnel shall com- pounding area during a work shift, the exterior plete didactic training, pass written competence as- gown may be removed and retained in the com- sessments, undergo skill assessment using pounding area if not visibly soiled, to be re-donned observational audit tools, and media-fill testing during that same work shift only. However, shoe (seeAppendices IIIV). covers, hair and facial hair covers, face masks/eye Media-fill testing of aseptic work skills shall be shields, and gloves shall be replaced with new performed initially before beginning to prepare ones before re-entering the compounding area, and CSPs and at least annually thereafter for low- and proper hand hygiene shall be performed. medium-risk level compounding and semiannually During high-risk compounding activities that for high-risk level compounding. precede terminal sterilization, such as weighing Compounding personnel who fail written tests or and mixing of nonsterile ingredients, compounding observational audits or whose media-fill test vials personnel shall be garbed and gloved the same as have one or more units showing visible microbial when performing compounding in an ISO Class 5 contamination shall be re-instructed and re-evalu- (see Table 1) environment. Properly garbed and ated by expert compounding personnel to ensure gloved compounding personnel who are exposed correction of all aseptic work practice deficiencies. to air quality that is either known or suspected to Compounding personnel shall pass all evaluations be worse than ISO Class 7 (see Table 1) shall re- prior to resuming compounding of sterile prepara- garb PPE along with washing their hands properly, tions. In addition to didactic evaluation and aseptic performing antiseptic hand cleansing with a water- media fill, compounding personnel must demon- less alcohol-based surgical hand scrub, and don- strate proficiency of proper hand hygiene, garbing, ning sterile gloves upon re-entering the ISO Class and consistent cleaning procedures. 7 (see Table 1) buffer area. When CAIs and In the event that cleaning and disinfecting proce- CACIs are the source of the ISO Class 5 (see Ta- dures are also performed by other support person- ble 1) environment, the garbing and gloving re- nel (e.g., institutional environmental services, quirements for compounding personnel should be housekeeping), thorough training of proper hand as described above, unless the isolator manufac- hygiene, garbing, and cleaning and disinfection turer can provide written documentation based on procedures shall be done by a qualified aseptic validated environmental testing that any compo- compounding expert. After completion of training, nent(s) of PPE or personnel cleansing are not support personnel shall routinely undergo perform- required. ance evaluation of proper hand hygiene, garbing, Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 31 and all applicable cleaning and disinfecting proce- tices (e.g., disinfection of component surfaces, routine disinfection of gloved hands). dures conducted by a qualified aseptic compound- Sterile contact agar plates shall be used to sam- ing expert. ple the gloved fingertips of compounding person- nel after garbing in order to assess garbing compe- COMPETENCY EVALUATION OF GARBING AND tency and after completing the media-fill ASEPTIC WORK PRACTICE preparation (without applying sterile 70% IPA) in order to assess the adequacy of aseptic work prac- The risk of contaminating a CSP prepared under tices prior to being initially allowed to prepare low-risk level and medium-risk level conditions is CSPs for human use and for more experienced per- highly dependent on proper hand hygiene and sonnel to maintain their qualifications to prepare garbing practices, compounding personnel aseptic CSPs for human use. technique, and the presence of surface contamina- Garbing And Gloving Competency tion, assuming that all work is performed in a cer- EvaluationCompounding personnel shall be vi- tified and properly functioning ISO Class 5 (see sually observed during the process of performing Table 1) PEC and secondary engineering controls, hand hygiene and garbing procedures (see Person- ISO Class 7 (see Table 1) buffer area, and ISO nel Cleansing and Garbing under Personnel Class 8 (see Table 1) ante-area. High-risk level Training and Evaluation in Aseptic Manipulation CSPs pose the greatest threat to patients because Skills above). The visual observation shall be doc- compounding personnel are tasked with the re- umented on a form such as the Sample Form for quirement of processing nonsterile components Assessing Hand Hygiene and Garbing Related and devices in order to achieve sterility. Com- Practices of Compounding Personnel (see Appen- pounding personnel shall be evaluated initially dix III) and maintained to provide a permanent rec- prior to beginning compounding CSPs and when- ord and long-term assessment of personnel ever an aseptic media fill is performed using a competency. form such as the Sample Form for Assessing Hand Gloved Fingertip SamplingAll compounding Hygiene and Garbing Related Practices of Com- personnel shall successfully complete an initial pounding Personnel (see Appendix III) and the competency evaluation and gloved fingertip/thumb personnel glove fingertip sampling procedures in- sampling procedure (zero cfu) no less than three dicated below. times before initially being allowed to compound Aseptic Work Practice Assessment and CSPs for human use. Immediately after the com- Evaluation via Personnel Glove Fingertip pounding employee completes the hand hygiene SamplingSampling of compounding personnel and garbing procedure (e.g., donning of sterile glove fingertips shall be performed for all CSP risk gloves prior to any disinfection with sterile 70% level compounding because direct touch contami- IPA), the evaluator will collect a gloved fingertip nation is the most likely source of introducing mi- and thumb sample from both hands of the com- croorganisms into CSPs prepared by humans. pounding employee onto appropriate agar plates Glove fingertip sampling shall be used to evaluate by lightly pressing each fingertip into the agar. the competency of personnel in performing hand The plates will be incubated for the appropriate in- hygiene and garbing procedures in addition to edu- cubation period and at the appropriate temperature cating compounding personnel on proper work (seeIncubation Period). After completing the ini- practices, which include frequent and repeated tial gowning and gloving competency evaluation, glove disinfection using sterile 70% IPA during re-evaluation of all compounding personnel for actual compounding of CSPs. All personnel shall this competency shall occur at least annually for demonstrate competency in proper hand hygiene personnel who compound low- and medium-risk and garbing procedures and in aseptic work prac- level CSPs and semi-annually for personnel who Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 32 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin compound high-risk level CSPs using one or more Media-Fill Test ProcedureThe skill of person- sample collections during any media-fill test nel to aseptically prepare CSPs shall be evaluated procedure before they are allowed to continue using sterile fluid bacterial culture media-fill veri- compounding CSPs for human use. fication, (i.e., sterile bacterial culture medium transfer via a sterile syringe and needle). Media- Immediately prior to sampling, gloves shall not fill testing is used to assess the quality of the asep- be disinfected with sterile 70% IPA. Disinfecting tic skill of compounding personnel. Media-fill gloves immediately before sampling will provide tests shall represent the most challenging or stress- false negative results. Plates filled with nutrient ful conditions actually encountered by the person- agar with neutralizing agents such as lecithin and nel being evaluated when they prepare low- and polysorbate 80 added shall be used when sampling medium-risk level CSPs and when sterilizing high- personnel fingertips. Personnel shall touch the risk level CSPs. Media-fill challenge tests are also agar with the fingertips of both hands in separate used to verify the capability of the compounding plates in a manner to create a slight impression in environment and processes to produce sterile the agar. The sampled gloves shall be immediately preparations. discarded and proper hand hygiene performed after A commercially available sterile fluid culture sampling. The nutrient agar plates shall be incu- media, such as SoybeanCasein Digest Medium bated as stated below (see Incubation Period). Re- (see Sterility Tests 71), that is able to promote sults should be reported separately as number of exponential colonization of bacteria that are most cfu per employee per hand (left hand, right hand). likely to be transmitted to CSPs from the com- The cfu action level for gloved hands will be based pounding personnel and environment is commonly on the total number of cfu on both gloves, not per used. For high-risk level CSPs nonsterile commer- hand. cially available SoybeanCasein Digest Medium Incubation PeriodAt the end of the desig- may be used to make a 3% solution. Normal nated sampling period for compounding personnel processing steps, including filter sterilization, shall competency assessment activities (surface or per- be mimicked. Media-filled vials shall be incubated sonnel), the agar plates are recovered and covers at 20 to 25 or at 30 to 35 for a minimum of 14 secured and they are inverted and incubated at a days. If two temperatures are used for incubation temperature and for a time period conducive to of media-filled samples, then these filled con- multiplication of microorganisms. TSA with leci- tainers should be incubated for at least 7 days at thin and polysorbate 80 shall be incubated at 30 each temperature (see Microbiological Evaluation to 35 for 48 to 72 hours. of Clean Rooms and Other Controlled Environ- Aseptic Manipulation Competency ments 1116). Failure is indicated by visible tur- EvaluationAfter successful completion of an bidity in any one of the media-fill units on or be- initial Hand Hygiene and Garbing Competency fore 14 days. Other methodologies recommended Evaluation, all compounding personnel shall have by a competent microbiologist to enhance recovery their aseptic technique and related practice compe- time and sensitivity to detect microbial contamina- tency evaluated initially during the Media-Fill Test tion may be considered (see CSP Microbial Con- Procedure and subsequent annual or semi-annual tamination Risk Levels for examples of media-fill Media-Fill Test Procedures. Records of these procedures). evaluations will be maintained using a form such as the Sample Form for Assessing Aseptic Tech- SURFACE CLEANING AND DISINFECTION SAMPLING nique and Related Practices of Compounding Per- AND ASSESSMENT sonnel (see Appendix IV) and maintained to pro- vide a permanent record of and long-term Surface sampling is an important component of assessment of personnel competency. the maintenance of a suitable microbially con- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 33 trolled environment for compounding CSPs, espe- with a nonshedding wipe soaked in sterile 70% cially since transfer of microbial contamination IPA. from improperly disinfected work surfaces via in- If an area is sampled via the swab method, col- advertent touch contact by compounding personnel lection of the sample is processed by using appro- can be a potential source of contamination into priate procedures that will result in the surface lo- CSPs. It is useful for evaluating facility and work cation equivalent to that of a contact plate. After surface cleaning and disinfecting procedures and swabbing the surface to be sampled, swabs are employee competency in work practices such as placed in an appropriate diluent; an aliquot is disinfection of component/vial surface cleaning. planted on or in the specified nutrient agar. Results Surface sampling shall be performed in all ISO should be reported as cfu per unit of surface area. classified areas on a periodic basis. Sampling can be accomplished using contact plates or swabs, Action Levels, Documentation, and Data and it shall be done at the conclusion of com- Evaluation pounding. Locations to be sampled shall be de- The value of viable microbial monitoring of fined in a sample plan or on a form. The size of the gloved fingertips and surfaces of components and plate to be used for each sampled location usually the compounding environment are realized when ranges from 24 to 30 cm 2 . Contact plates are filled the data are used to identify and correct an unac- with general solid agar growth medium and neu- ceptable work practice. Sampling data shall be col- tralizing agents above the rim of the plate, and lected and reviewed on a routine basis as a means they are used for sampling regular or flat surfaces. of evaluating the overall control of the compound- Swabs may be used for sampling irregular sur- ing environment. If an activity consistently shows faces, especially for equipment (see Microbiologi- elevated levels of microbial growth, competent mi- cal Evaluation of Clean Rooms and Other Con- crobiology personnel shall be consulted. trolled Environments 1116). Any cfu count that exceeds its respective action Cleaning and Disinfecting Competency level (see Table 4) should prompt a re-evaluation EvaluationCompounding personnel and other of the adequacy of personnel work practices, personnel responsible for cleaning shall be visually cleaning procedures, operational procedures, and observed during the process of performing clean- air filtration efficiency within the aseptic com- ing and disinfecting procedures, during initial per- pounding location. An investigation into the sonnel training on cleaning procedures, during source of the contamination shall be conducted. changes in cleaning staff, and at the completion of Sources could include HVAC systems, damaged any media-fill test procedure (see Cleaning and HEPA filters, and changes in personnel garbing or Disinfecting of Compounding Areas). working practices. The source of the problem shall The visual observation shall be documented us- be eliminated, the affected area cleaned, and ing a form such as the Sample Form for Assessing resampling performed. Cleaning and Disinfection Procedures (see Appen- When gloved fingertip sample results exceed ac- dix V) and maintained to provide a permanent rec- tion levels after proper incubation, a review of ord and long-term assessment of personnel hand hygiene and garbing procedures as well as competency. glove and surface disinfection procedures and Surface Collection MethodsTo sample sur- work practices shall be performed and docu- faces using a contact plate, gently touch the sam- mented. Employee training may be required to cor- ple area with the agar surface and roll the plate rect the source of the problem. across the surface to be sampled. The contact plate will leave a growth media residue behind; there- Counts of cfu are to be used as an approximate fore, immediately after sampling with the contact measure of the environmental microbial bi- plate, the sampled area shall be thoroughly wiped oburden. Action levels are determined on the basis Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 34 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin of cfu data gathered at each sampling location and and properly disinfected cart or other convey- trended over time. The numbers in Table 4 should ance for introduction into the buffer area. be used only as guidelines. Regardless of the num- Manufacturers directions or published data ber of cfu identified in the compounding facility, for minimum contact time will be followed. further corrective actions will be dictated by the Individual pouched sterile supplies need not identification of microorganisms recovered (at be wiped because the pouches can be re- least the genus level) by an appropriate creden- moved as these sterile supplies are introduced tialed laboratory of any microbial bioburden cap- into the buffer area. tured as a cfu using an impaction air sampler. 3. Supplies that are required frequently or other- Highly pathogenic microorganisms (e.g., Gram- wise needed close at hand but not necessarily negative rods, coagulase positive staphylococcus, needed for the scheduled operations of the molds and yeasts) can be potentially fatal to pa- shift are decontaminated and stored on shelv- tients receiving CSPs and shall be immediately ing in the ante-area. remedied, regardless of cfu count, with the assis- 4. Carts used to bring supplies from the store- tance of a competent microbiologist, infection con- room cannot be rolled beyond the demarca- trol professional, or industrial hygienist. tion line in the ante-area, and carts used in the buffer area cannot be rolled outward beyond Table 4. Recommended Action Levels for the demarcation line unless cleaned and disin- Microbial Contamination * fected before returning. Classification Fingertip Surface Sample 5. Generally, supplies required for the scheduled Sample (Contact Plate) operations of the shift are wiped down with (cfu per plate) an appropriate disinfecting agent and brought into the buffer area, preferably on one or more ISO Class 5 >3 >3 movable carts. Supplies that are required for ISO Class 7 N/A >5 back-up or general support of operations may ISO Class 8 or N/A >100 be stored on the designated shelving in the worse buffer area, but excessive amounts of supplies * Pharmaceutical Inspection Co-operation Scheme (PIC/S) Guide to Good Manufacturing Practice for Medicinal Products Annex- are to be avoided. es PE 009-6, 5 April 2007. 6. Nonessential objects that shed particles shall not be brought into the buffer area, including pencils, cardboard cartons, paper towels, and SUGGESTED STANDARD OPERATING cotton items (e.g., gauze pads). PROCEDURES (SOPs) 7. Essential paper-related products (e.g., paper The compounding facility shall have written, syringe overwraps, work records contained in properly approved SOPs designed to ensure the a protective sleeve) shall be wiped down with quality of the environment in which a CSP is pre- an appropriate disinfecting agent prior to be- pared. The following procedures are ing brought into the buffer area. recommended: 8. Traffic flow in and out of the buffer area shall 1. Access to the buffer area is restricted to quali- be minimized. fied personnel with specific responsibilities or 9. Personnel preparing to enter the buffer area assigned tasks in the compounding area. shall remove all personal outer garments, cos- 2. All cartoned supplies are decontaminated in metics (because they shed flakes and parti- the area by removing them from shipping car- cles), and all hand, wrist, and other visible tons and wiping or spraying them with a jewelry or piercings that can interfere with the nonresidue-generating disinfecting agent effectiveness of PPE. while they are being transferred to a clean 10. Personnel entering the ante-area shall don at- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 35 tire as described in Personnel Cleansing and as to reduce clutter and provide maximum ef- Garbing and Personnel Training and Compe- ficiency and order for the flow of work. tency Evaluation of Garbing, Aseptic Work 19. After proper introduction into the DCA of Practices and Cleaning/Disinfection Pro- supply items required for and limited to the cedures. assigned operations, they are so arranged that 11. Personnel shall then thoroughly wash hands a clear, uninterrupted path of HEPA-filtered and forearms to the elbow with soap and wa- air will bathe all critical sites at all times dur- ter for at least 30 seconds. An air dryer or dis- ing the planned procedures. That is, no ob- posable nonshedding towels are used to dry jects may be placed between the first air from hands and forearms after washing. HEPA filters and an exposed critical site. 12. Personnel entering the buffer area shall per- 20. All procedures are performed in a manner de- form antiseptic hand cleansing prior to don- signed to minimize the risk of touch contami- ning sterile gloves using a waterless alcohol- nation. Gloves are disinfected with adequate based surgical hand scrub with persistent frequency with an approved disinfectant such activity. as sterile 70% IPA. 13. Chewing gum, drinks, candy, or food items 21. All rubber stoppers of vials and bottles and shall not be brought into the buffer area or the necks of ampuls are disinfected by wiping ante-area. Materials exposed in patient care with sterile 70% IPA and waiting for at least and treatment areas shall never be introduced 10 seconds before they are used to prepare into areas where components and ingredients CSPs. for CSPs are present. 22. After the preparation of every CSP, the con- 14. At the beginning of each compounding activ- tents of the container are thoroughly mixed ity session, and whenever liquids are spilled, and then inspected for the presence of particu- the surfaces of the direct compounding envi- late matter, evidence of incompatibility, or ronment are first cleaned with USP Purified other defects. Water to remove water-soluble residues. Im- 23. After procedures are completed, used syr- mediately thereafter, the same surfaces are inges, bottles, vials, and other supplies are re- disinfected with a nonresidue-generating moved, but with a minimum of exit and re- agent using a nonlinting wipe. entry into the DCA so as to minimize the risk 15. Primary engineering controls shall be oper- of introducing contamination into the aseptic ated continuously during compounding activ- workspace. ity. When the blower is turned off and before other personnel enter to perform compound- ELEMENTS OF QUALITY CONTROL ing activities, only one person shall enter the buffer area for the purposes of turning on the A written description of specific training and blower (for at least 30 minutes) and disinfect- performance evaluation program for individuals ing the work surfaces. involved in the use of aseptic techniques for the 16. Traffic in the area of the DCA is minimized preparation of sterile products shall be developed and controlled. for each site. This program equips personnel with 17. Supplies used in the DCA for the planned the appropriate knowledge and trains them in the procedures are accumulated and then decon- required skills necessary to perform the assigned taminated by wiping or spraying the outer sur- tasks. Each person assigned to the aseptic area in face with sterile 70% IPA or removing the the preparation of sterile products shall success- outer wrap at the edge of the DCA as the item fully complete specialized training in aseptic tech- is introduced into the aseptic work area. niques and aseptic area practices prior to preparing 18. All supply items are arranged in the DCA so CSPs (see Personnel Training and Evaluation in Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 36 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Aseptic Manipulation Skills and Personnel Train- be clearly and indelibly marked on each package ing and Competency Evaluation of Garbing, Asep- of ingredient. After receipt by the compounding tic Work Practices and Cleaning/Disinfection facility, packages of ingredients that lack a suppli- Procedures). ers expiration date cannot be used after 1 year un- less either appropriate inspection or testing indi- cates that the ingredient has retained its purity and Ingredients and Devices quality for use in CSPs. Compounding personnel ascertain that ingredi- Careful consideration and evaluation of nonster- ents for CSPs are of the correct identity and appro- ile ingredient sources is especially warranted when priate quality using the following information: the CSP will be administered into the vascular sys- vendor labels, labeling, certificates of analysis, di- tem, central nervous system, or eyes. rect chemical analysis, and knowledge of com- Upon receipt of each lot of the bulk drug sub- pounding facility storage conditions. stance or excipient used for CSPs, the individual compounding the preparation performs a visual in- STERILE INGREDIENTS AND DEVICES spection of the lot for evidence of deterioration, Commercially available sterile drug products, other types of unacceptable quality, and wrong sterile ready-to-use containers, and devices are ex- identification. For bulk drug substances or excipi- amples of sterile components. A written procedure ents, visual inspection is performed on a routine for unit-by-unit physical inspection preparatory to basis as described in the written protocol. use is followed to ensure that these components are sterile, free from defects, and otherwise suit- Equipment able for their intended use. It is necessary that equipment, apparatus, and de- NONSTERILE INGREDIENTS AND DEVICES vices used to compound a CSP be consistently ca- pable of operating properly and within acceptable If any nonsterile components, including con- tolerance limits. Written procedures outlining re- tainers and ingredients, are used to make a CSP, quired equipment calibration, annual maintenance, such CSPs must be high risk. Nonsterile active in- monitoring for proper function, and controlled pro- gredients and added substances or excipients for cedures for use of the equipment and specified CSPs should preferably be official USP or NF arti- time frames for these activities are established and cles. When nonofficial ingredients are used, they followed. Routine maintenance and frequencies shall be accompanied by certificates of analysis shall be outlined in these SOPs. Results from the from their suppliers to aid compounding personnel equipment calibration, annual maintenance reports, in judging the identity, quality, and purity in rela- and routine maintenance are kept on file for the tion to the intended use in a particular CSP. Physi- lifetime of the equipment. Personnel are prepared cal inspection of a package of ingredients is neces- through an appropriate combination of specific sary in order to detect breaks in the container, training and experience to operate or manipulate looseness in the cap or closure, and deviation from any piece of equipment, apparatus, or device they the expected appearance, aroma, and texture of the may use when preparing CSPs. Training includes contents. gaining the ability to determine whether any item Bulk or unformulated drug substances and added of equipment is operating properly or is substances or excipients shall be stored in tightly malfunctioning. closed containers under temperature, humidity, and lighting conditions that are either indicated in official monographs or approved by suppliers. The VERIFICATION OF AUTOMATED date of receipt by the compounding facility shall COMPOUNDING DEVICES (ACDs) FOR Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 37 PARENTERAL NUTRITION racy is then weighed on the balance used in con- COMPOUNDING junction with the ACD. For example, if 40 mL of water was used in the volumetric assessment, its ACDs for the preparation of parenteral nutrition corresponding weight should be about 40g (as- admixtures are widely used by pharmacists in hos- suming the relative density of water is 1.0). In ad- pitals and other healthcare settings. They are de- dition, during the use of the ACD, certain addi- signed to streamline the labor-intensive processes tives, such as potassium chloride (corrected for involved in the compounding of these multiple- density differences), can also be tested in the same component formulations by automatically deliver- manner as with an in-process test. ing the individual nutritional components in a pre- Finally, additional tests of accuracy may be em- determined sequence under computerized control. ployed that determine the content of certain in- Parenteral nutrition admixtures often contain 20 or gredients in the final volume of the parenteral nu- more individual additives representing as many as trition admixture. Generally, pharmacy 50 or more individual components (e.g., 15 to 20 departments do not have the capability to routinely crystalline amino acids, dextrose monohydrate, perform chemical analyses such as analyses of and lipids; 10 to 12 electrolyte salts; 5 to 7 trace dextrose or electrolyte concentrations. Conse- minerals; and 12 vitamins). Thus, ACDs can pro- quently, hospital or institutional laboratories may vide improved accuracy and precision of the com- be called upon to perform these quality assurance pounding process over the traditional manual com- tests. However, the methods in such laboratories pounding methods. are often designed for biological, not pharmaceuti- cal, systems. Thus, their testing procedures shall be verified to meet the USP requirements stated in Accuracy the individual monograph for the component being The accuracy of an ACD can be determined in tested. For example, under Dextrose Injection, the various ways to ensure that the correct quantities following is stated: It contains not less than 95.0% of nutrients, electrolytes, or other nutritional com- and not more than 105.0% of the labeled amount ponents are delivered to the final infusion con- of C 6 H 12 O 6 H 2 O. The hospital or institutional tainer. Initially, the ACD is tested for its volume chemistry laboratories must validate their methods and weight accuracy. For volume accuracy, a suit- to apply to this range and correct for their typical able volume of Sterile Water for Injection, USP, measurement of anhydrous dextrose versus dex- which represents a typical additive volume (e.g., trose monohydrate. Similar ranges and issues exist, 40 mL for small-volume range of 1 to 100 mL, for example, for injections of calcium gluconate, 300 mL for large-volume range of 100 to 1000 magnesium sulfate, and potassium chloride. The mL), is programmed into the ACD and delivered critical point is the use of USP references and pos- to the appropriate volumetric container. The com- sible laboratory procedural differences. pounding personnel should then consult Volu- metric Apparatus 31 for appropriate parameters Precision to assess the volumetric performance of the ACD. For gravimetric accuracy, the balance used in con- The intermediate precision of the ACD can be junction with the ACD is tested using various determined on the basis of the day-to-day varia- weight sizes that represent the amounts typically tions in performance of the accuracy measures. used to deliver the various additives. Compound- Thus, compounding personnel shall keep a daily ing personnel should consult Weights and Bal- record of the above-described accuracy assess- ances 41 for acceptable tolerances of the weights ments and review the results over time. This re- used. In addition, the same volume of Sterile Wa- view shall occur at least at weekly intervals to ter for Injection used to assess volumetric accu- avoid potentially clinically significant cumulative Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 38 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin errors over time. This is especially true for addi- CSP with defects, such as precipitation, cloudi- tives with a narrow therapeutic index, such as ness, and leakage, which may develop between the potassium chloride. time of release and the time of distribution, is not released. FINISHED PREPARATION RELEASE Compounding Accuracy Checks CHECKS AND TESTS Written procedures for double-checking com- The following quality metrics shall be performed pounding accuracy shall be followed for every for all CSPs before they are dispensed or CSP during preparation and immediately prior to administered. release. The double-check system should meet state regulations and include label accuracy and Inspection of Solution Dosage Forms and accuracy of the addition of all drug products or in- Review of Compounding Procedures gredients used to prepare the finished product and All CSPs that are intended to be solutions shall their volumes or quantities. The used additive con- be visually examined for the presence of particu- tainers and, for those additives for which the entire late matter and not administered or dispensed container was not expended, the syringes used to when such matter is observed. The prescription or- measure the additive should be quarantined with ders, written compounding procedure, preparation the final products until the final product check is records, and expended materials used to make completed. Compounding personnel shall visually CSPs at all contamination risk levels are inspected confirm that ingredients measured in syringes for accuracy of correct identities and amounts of match the written order being compounded. Pref- ingredients, aseptic mixing and sterilization, pack- erably, a person other than the compounder can aging, labeling, and expected physical appearance verify that correct volumes of correct ingredients before they are administered or dispensed. were measured to make each CSP. For example, compounding personnel would pull the syringe PHYSICAL INSPECTION plunger back to the volume measured. When practical, the accuracy of measurements is Finished CSPs are individually inspected in ac- confirmed by weighing a volume of the measured cordance with written procedures after compound- fluid, then calculating that volume by dividing the ing. If not distributed promptly, these CSPs are weight by the accurate value of the density, or spe- individually inspected just prior to leaving the cific gravity, of the measured fluid. Correct den- storage area. Those CSPs that are not immediately sity or specific gravity values programmed in distributed are stored in an appropriate location as ACDs, which measure by weight using the quo- described in the written procedures. Immediately tient of the programmed volume divided by the after compounding, and as a condition of release, density or specific gravity, shall be confirmed to each CSP unit, where possible, should be in- be accurate before and after delivering volumes of spected against lighted white or black background the liquids assigned to each channel or port. These or both for evidence of visible particulates or other volume accuracy checks and the following addi- foreign matter. Prerelease inspection also includes tional safety and accuracy checks in this section containerclosure integrity and any other apparent shall be included in the SOP manual of the CSP visual defect. CSPs with observed defects should facility. be immediately discarded or marked and segre- gated from acceptable products in a manner that Sterility Testing prevents their administration. When CSPs are not distributed promptly after preparation, a predis- All high-risk level CSPs that are prepared in tribution inspection is conducted to ensure that a groups of more than 25 identical individual single- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 39 dose packages (e.g., ampuls, bags, syringes, vials) graph or other CSP formula source, the CSP shall or in multiple-dose vials (MDVs) for administra- not exceed the amount of USP Endotoxin Units tion to multiple patients or that are exposed longer (per hour per kilogram of body weight or square than 12 hours at 2 to 8 and longer than 6 hours at meters of body surface area) specified in Bacterial warmer than 8 before they are sterilized shall Endotoxins Test 85 referenced above for the ap- meet the sterility test (see Sterility Tests 71) be- propriate route of administration. fore they are dispensed or administered. The Identity and Strength Verification of Membrane Filtration method is the method of Ingredients choice where feasible (e.g., components are com- patible with the membrane). A method not de- Compounding facilities shall have at least the scribed in the USP may be used if verification re- following written procedures for verifying the cor- sults demonstrate that the alternative is at least as rect identity and quality of CSPs before they are effective and reliable as the USP Membrane Fil- dispensed and administered: tration method or the USP Direct Inoculation of 1. That labels of CSPs bear correct names and the Culture Medium method where the Membrane amounts or concentrations of ingredients, the Filtration method is not feasible. total volume, the BUD, the appropriate When high-risk level CSPs are dispensed before route(s) of administration, the storage condi- receiving the results of their sterility tests, there tions, and other information for safe use. shall be a written procedure requiring daily obser- 2. That there are correct identities, purities, and vation of the incubating test specimens and im- amounts of ingredients by comparing the mediate recall of the dispensed CSPs when there is original written order with the written com- any evidence of microbial growth in the test speci- pounding record for the CSP. mens. In addition, the patient and the physician of 3. That correct fill volumes in CSPs and correct the patient to whom a potentially contaminated quantities of filled units of the CSPs were ob- CSP was administered are notified of the potential tained. When the strength of finished CSPs risk. Positive sterility test results should prompt a cannot be confirmed to be accurate, based on rapid and systematic investigation of aseptic tech- the above three inspections, the CSPs shall be nique, environmental control, and other sterility assayed by methods that are specific for the assurance controls to identify sources of contami- active ingredients. nation and correct problems in the methods or processes. STORAGE AND BEYOND-USE DATING BUDs for compounded preparations are usually Bacterial Endotoxin (Pyrogen) Testing assigned on the basis of professional experience, All high-risk level CSPs, except those for inhala- which should include careful interpretation of ap- tion and ophthalmic administration, that are pre- propriate information sources for the same or simi- pared in groups of more than 25 identical individ- lar formulations (see Stability Criteria and Be- ual single-dose packages (e.g., ampuls, bags, yond-Use Dating under Pharmaceutical syringes, vials) or in MDVs for administration to CompoundingNonsterile Preparations 795). multiple patients or that are exposed longer than BUDs for CSPs are rarely based on preparation- 12 hours at 2 to 8 and longer than 6 hours at specific chemical assay results, which are used warmer than 8 before they are sterilized shall be with the Arrhenius equation to determine expira- tested to ensure that they do not contain excessive tion dates (see General Notices and Requirements) bacterial endotoxins (see Bacterial Endotoxins for manufactured products. The majority of CSPs Test 85 and Pyrogen Test 151). In the absence are aqueous solutions in which hydrolysis of dis- of a bacterial endotoxins limit in the official mono- solved ingredients is the most common chemical Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 40 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin degradation reaction. The extent of hydrolysis and propriate literature sources or direct testing. BUDs other heat-catalyzed degradation reactions at any for CSPs that lack justification from either appro- particular time point in the life of a CSP represents priate literature sources or by direct testing evi- the thermodynamic sum of exposure temperatures dence shall be assigned as described in Stability and durations. Such lifetime stability exposure is Criteria and Beyond-Use Dating under Pharma- represented in the mean kinetic temperature calcu- ceutical CompoundingNonsterile Preparations lation (see Pharmaceutical Calculations in Pre- 795. scription Compounding 1160). Drug hydrolysis In addition, compounding personnel may refer to rates increase exponentially with arithmetic tem- applicable publications to obtain relevant stability, perature increase; thus, exposure of a beta-lactam compatibility, and degradation information regard- antibiotic solution for 1 day at controlled room ing the drug or its congeners. When assigning a temperature (see General Notices and Require- beyond-use date, compounding personnel should ments) will have an equivalent effect on the extent consult and apply drug-specific and general stabil- of hydrolysis of approximately 3 to 5 days in cold ity documentation and literature where available, temperatures (see General Notices and and they should consider the nature of the drug Requirements). and its degradation mechanism, the container in which it is packaged, the expected storage condi- Personnel who prepare, dispense, and administer tions, and the intended duration of therapy (see Ex- CSPs shall store them strictly in accordance with piration Date and Beyond-Use Date under Label- the conditions stated on the label of ingredient ing in the General Notices and Requirements). products and finished CSPs. When CSPs are Stability information must be carefully interpreted known to have been exposed to temperatures in relation to the actual compounded formulation warmer than the warmest labeled limit or to tem- and conditions for storage and use. Predictions peratures exceeding 40 (see General Notices and based on other evidence, such as publications, Requirements) for more than 4 hours, such CSPs charts, and tables, would result in theoretical should be discarded unless direct assay data or ap- BUDs. Theoretically predicted beyond-use dating propriate documentation confirms their continued introduces varying degrees of assumptions and, stability. hence, a likelihood of error or at least inaccuracy. The degree of error or inaccuracy would be de- Determining Beyond-Use Dates pendent on the extent of differences between the BUDs and expiration dates are not the same (see CSPs characteristics (e.g., composition, concen- General Notices and Requirements). Expiration tration of ingredients, fill volume, container type dates for the chemical and stability of manufac- and material) and the characteristics of the prod- tured sterile products are determined from results ucts from which stability data or information is to of rigorous analytical and performance testing, and be extrapolated. The greater the doubt of the accu- they are specific for a particular formulation in its racy of theoretically predicted beyond-use dating, container and at stated exposure conditions of illu- the greater the need to determine dating periods mination and temperature. When CSPs deviate experimentally. Theoretically predicted beyond- from conditions in the approved labeling of manu- use dating periods should be carefully considered factured products contained in CSPs, compound- for CSPs prepared from nonsterile bulk active in- ing personnel may consult the manufacturer of gredients having therapeutic activity, especially particular products for advice on assigning BUDs where these CSPs are expected to be compounded based on chemical and physical stability parame- routinely. When CSPs will be distributed to and ters. BUDs for CSPs that are prepared strictly in administered in residential locations other than accordance with manufacturers product labeling healthcare facilities, the effect of potentially un- shall be those specified in that labeling or from ap- controlled and unmonitored temperature condi- Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 41 tions shall be considered when assigning BUDs. It carried over to the compounded or admixed prepa- must be ascertained that CSPs will not be exposed ration. Preparation-specific, experimentally deter- to warm temperatures (see General Notices and mined stability data evaluation protocols are pref- Requirements) unless the compounding facility has erable to published stability information. evidence to justify stability of CSPs during such Compounding personnel should consult general in- exposure. formation chapter Pharmaceutical Stability It should be recognized that the truly valid evi- 1150 for the appropriate stability parameters to dence of stability for predicting beyond-use dating be considered when initiating or evaluating a prep- can be obtained only through product-specific ex- aration-specific stability study. perimental studies. Semiquantitative procedures Compounding personnel who assign BUDs to such as thin-layer chromatography (TLC) may be CSPs when lacking direct chemical assay results acceptable for many CSPs. However, quantitative must critically interpret and evaluate the most ap- stability-indicating assays such as high-perform- propriate available information sources to deter- ance liquid chromatographic (HPLC) assays would mine a conservative and safe BUD. The SOP man- be more appropriate for certain CSPs. Examples ual of the compounding facility and each specific include CSPs with a narrow therapeutic index, CSP formula record shall describe the general ba- where close monitoring or dose titration is re- sis used to assign the BUD and storage conditions. quired to ensure therapeutic effectiveness and to avoid toxicity; where a theoretically established When manufactured MDVs (see Multiple-Dose beyond-use dating period is supported by only Container under Preservation, Packaging, Stor- marginal evidence; or where a significant margin age, and Labeling in the General Notices and Re- of safety cannot be verified for the proposed be- quirements) of sterile ingredients are used in CSPs, yond-use dating period. In short, because beyond- the stoppers of the MDVs are inspected for physi- use dating periods established from product-spe- cal integrity and disinfected by wiping with a ster- cific data acquired from the appropriate instrumen- ile 70% IPA swab before each penetration with a tal analyses are clearly more reliable than those sterile withdrawal device. When contaminants or predicted theoretically, the former approach is abnormal properties are suspected or observed in strongly urged to support dating periods exceeding MDVs, such MDVs shall be discarded. The BUD 30 days. after initially entering or opening (e.g., needle To ensure consistent practices in determining puncturing) multiple-dose containers is 28 days and assigning BUDs, the compounding facility (see Antimicrobial Effectiveness Testing 51) un- should have written policies and procedures gov- less otherwise specified by the manufacturer. erning the determination of the BUDs for all com- pounded products. When attempting to predict a theoretical BUD, a compounded or an admixed Proprietary Bag and Vial Systems preparation should be considered as a unique sys- The sterility storage and stability beyond-use tem that has physical and chemical properties and times for attached and activated (where activated stability characteristics that differ from its compo- is defined as allowing contact of the previously nents. For example, antioxidant, buffering, or anti- separate diluent and drug contents) container pairs microbial properties of a sterile vial for injection of drug products for intravascular administration (SVI) might be lost upon its dilution, with the po- (e.g., ADD-Vantage
, Mini Bag Plus
) shall be tential of seriously compromising the chemical sta-
applied as indicated by the manufacturer. In other bility of the SVIs active ingredient or the physical words, follow manufacturers instructions for han- or microbiological stability of the SVI formulation dling and storing ADD-Vantage
, Mini Bag Plus
, in general. Thus, the properties stabilized in the
Add A Vial
, Add-Ease
products, and any others. SVI formulation usually cannot be expected to be
Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 42 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Monitoring Controlled Storage Areas MAINTAINING STERILITY, PURITY, AND To ensure that product potency is retained STABILITY OF DISPENSED AND through the manufacturers labeled expiration date, DISTRIBUTED CSPs compounding personnel shall monitor the drug This section summarizes the responsibilities of storage areas within the compounding facility. compounding facilities for maintaining quality and Controlled temperature areas in compounding control of CSPs that are dispensed and adminis- facilities include controlled room temperature, 20 tered within their parent healthcare organizations. to 25 with mean kinetic temperature 25; Compounding personnel shall ensure proper controlled cold temperature, 2 to 8 with mean storage and security of CSPs prepared by or dis- kinetic temperature 8; cold temperature, 2 to 8; pensed from the compounding facility until either freezing temperature, 25 and 10 (see General their BUDs are reached or they are administered to Notices and Requirements) if needed to achieve patients. In fulfilling this general responsibility, freezing, and the media-specific temperature range the compounding facility is responsible for the for microbial culture media. A controlled proper packaging, handling, transport, and storage temperature area shall be monitored at least once of CSPs prepared by or dispensed from it, includ- daily and the results documented on a temperature ing the appropriate education, training, and super- log. Additionally, compounding personnel shall vision of compounding personnel assigned to these note the storage temperature when placing the functions. The compounding facility should assist product into or removing the product from the in the education and training of noncompounding storage unit in order to monitor any temperature personnel responsible for carrying out any aspect aberrations. Suitable temperature recording of these functions. devices may include a calibrated continuous recording device or a National Institute of Establishing, maintaining, and ensuring compli- Standards and Technology (NIST) calibrated ance with comprehensive written policies and pro- thermometer that has adequate accuracy and cedures encompassing these responsibilities is a sensitivity for the intended purpose, and it shall be further responsibility of the compounding facility. properly calibrated at suitable intervals. If the Where noncompounding personnel are assigned compounding facility uses a continuous tasks involving any of these responsibilities, the temperature recording device, compounding policies and procedures encompassing those tasks personnel shall verify at least once daily that the should be developed by compounding supervisors. recording device itself is functioning properly. The quality and control activities related to distri- The temperature-sensing mechanisms shall be bution of CSPs are summarized in the following suitably placed in the controlled temperature five subsections. Activities or concerns that should storage space to reflect accurately its true be addressed as the compounding facility fulfills temperature. In addition, the compounding facility these responsibilities are as follows. shall adhere to appropriate procedures of all controlled storage spaces to ensure that such Packaging, Handling, and Transport spaces are not subject to significantly prolonged temperature fluctuations as may occur, for Inappropriate processes or techniques involved example, by leaving a refrigerator door open too with packaging, handling, and transport can ad- long. versely affect quality and package integrity of CSPs. Although compounding personnel routinely perform many of the tasks associated with these functions, some tasks, such as transport, handling, and placement into storage, may be fulfilled by noncompounding personnel who are not under the Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 43 direct administrative control of the compounding potential breakage and contamination. Special re- facility. Under these circumstances, appropriate quirements associated with the packaging, trans- SOPs shall be established by the compounding fa- port, and handling of these agents include the pre- cility with the involvement of other departments or vention of accidental exposures or spills and the services whose personnel are responsible for carry- training of personnel in the event of an exposure or ing out those CSP-related functions for which the spill. Examples of special requirements of these compounding facility has a direct interest. The per- agents also include exposure-reducing strategies formance of the noncompounding personnel is such as the use of Luer lock syringes and connec- monitored for compliance to established policies tions, syringe caps, the capping of container ports, and procedures. sealed plastic bags, impact-resistant containers, The critical requirements that are unique to CSPs and cautionary labeling. and that are necessary to ensure CSP quality and Use and Storage packaging integrity shall be addressed in SOPs. For example, techniques should be specified to The compounding facility is responsible for en- prevent the depression of syringe plungers or dis- suring that CSPs in the patient-care setting main- lodging of syringe tips during handling and trans- tain their quality until administered. The immedi- port. Additionally, disconnection of system com- ate labeling of the CSP container will display ponents (e.g., where CSPs are dispensed with prominently and understandably the requirements administration sets attached to them) shall be pre- for proper storage and expiration dating. Delivery vented through the BUD of the CSP. Foam pad- and patient-care-setting personnel shall be prop- ding or inserts are particularly useful where CSPs erly trained to deliver the CSP to the appropriate are transported by pneumatic tube systems. Re- storage location. Outdated and unused CSPs shall gardless of the methods used, the compounding fa- be returned to the compounding facility for cility must evaluate their effectiveness and the reli- disposition. ability of the intended protection. Evaluation SOPs must exist to ensure that storage conditions should be continuousfor example, through a sur- in the patient-care setting are suitable for the CSP- veillance system, including a system of problem specific storage requirements. Procedures include reporting to the compounding facility. daily monitoring and documentation of drug stor- Inappropriate transport and handling can ad- age refrigerators to ensure temperatures between versely affect the quality of certain CSPs having 2 and 8 and the monthly inspection of all drug unique stability concerns. For example, the physi- storage locations by compounding personnel. In- cal shaking that might occur during pneumatic spections shall confirm compliance with appropri- tube transport or undue exposure to heat or light ate storage conditions, separation of drugs and must be addressed on a preparation-specific basis. food, proper use of MDVs, and the avoidance of Alternative transport modes or special packaging using single-dose products as MDVs. CSPs, as measures might be needed for the proper assurance well as all other drug products, shall be stored in of quality of these CSPs. The use of tamper-evi- the patient-care area in such a way as to secure dent closures and seals on CSP ports can add an them from unauthorized personnel, visitors, and additional measure of security to ensure product patients. integrity regardless of the transport method used. Chemotoxic and other hazardous CSPs require Readying for Administration safeguards to maintain the integrity of the CSP and to minimize the exposure potential of these prod- Procedures essential for generally ensuring qual- ucts to the environment and to personnel who may ity, especially sterility assurance, when readying a come in contact with them. Transportation by CSP for its subsequent administration include pneumatic tube should be discouraged because of proper hand washing, aseptic technique, site care, Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 44 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin and change of administration sets. Additional pro- Education and Training cedures may also be essential for certain CSPs, de- The assurance of CSPs quality and packaging vices, or techniques. Examples where such special integrity is highly dependent on the proper adher- procedures are needed include in-line filtration, the ence of all personnel to the pertinent SOPs. Com- operation of automated infusion control devices, pounding personnel shall design, implement, and and the replenishment of CSPs into the reservoirs maintain a formal education, training, and compe- of implantable or portable infusion pumps. When tency assessment program that encompasses all the CSPs are likely to be exposed to warmer than 30 functions and tasks addressed in the foregoing sec- for more than 1 hour during their administration to tions and all personnel to whom such functions patients, the maintenance of their sterility and sta- and tasks are assigned. This program includes the bility should be confirmed from either relevant and assessment and documentation of procedural reliable sources or direct testing. breaches, administration mishaps, side effects, al- lergic reactions, and complications associated with Redispensed CSPs dosage or administration, such as extravasation. The compounding facility shall have the sole au- This program should be coordinated with the insti- thority to determine when unopened, returned tutions adverse-events and incident reporting CSPs may be redispensed. Returned CSPs may be programs. redispensed only when personnel responsible for Packing and Transporting CSPs sterile compounding can ensure that such CSPs are sterile, pure, and stable (contain labeled strength of The following sections describe how to maintain ingredients). The following may provide such as- sterility and stability of CSPs until they are deliv- surance: the CSPs were maintained under continu- ered to patient care locations for administration. ous refrigeration and protected from light, if re- quired, and no evidence of tampering or any PACKING CSPs FOR TRANSIT readying for use outside the compounding facility exists. Assignment of new storage times and When CSPs are distributed to locations outside BUDs that exceed the original dates for returned the premises in which they are compounded, com- CSPs is permitted only when there is supporting pounding personnel select packing containers and evidence from sterility testing and quantitative as- materials that are expected to maintain physical in- say of ingredients. Thus, initial preparation and tegrity, sterility, and stability of CSPs during thaw times should be documented and reliable transit. Packing is selected that simultaneously measures should have been taken to prevent and protects CSPs from damage, leakage, contamina- detect tampering. Compliance with all procedures tion, and degradation, and protects personnel who associated with maintaining product quality is es- transport packed CSPs from harm. The SOP man- sential. The CSPs shall not be redispensed if there ual of the compounding facility specifically de- is not adequate assurance that preparation quality scribes appropriate packing containers and insulat- and packaging integrity (including the connections ing and stuffing materials, based on information of devices, where applicable) were continuously from product specifications, vendors, and experi- maintained between the time the CSPs left and the ence of compounding personnel. Written instruc- time they were returned. Additionally, CSPs shall tions that clearly explain how to safely open con- not be redispensed if redispensing cannot be sup- tainers of packed CSPs are provided to patients ported by the originally assigned BUD. and other recipients. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 45 TRANSIT OF CSPs tional objectives for the training program include all home care responsibilities expected of the pa- Compounding facilities that ship CSPs to loca- tient or caregiver and is specified in terms of pa- tions outside their own premises shall select modes tient or caregiver competencies. of transport that are expected to deliver properly Upon the conclusion of the training program, the packed CSPs in undamaged, sterile, and stable patient or caregiver should, correctly and consis- condition to recipients. tently, be able to do the following: Compounding personnel should ascertain that 1. Describe the therapy involved, including the temperatures of CSPs during transit by the selected disease or condition for which the CSPs are mode will not exceed the warmest temperature prescribed, goals of therapy, expected thera- specified on the storage temperature range on CSP peutic outcome, and potential side effects of labels. It is recommended that compounding per- the CSPs. sonnel communicate directly with the couriers to 2. Inspect all drug products, CSPs, devices, learn shipping durations and exposure conditions equipment, and supplies on receipt to ensure that CSPs may encounter. that proper temperatures were maintained dur- Compounding personnel shall include specific ing transport and that goods received show no handling and exposure instructions on the exteriors evidence of deterioration or defects. of containers packed with CSPs to be transported 3. Handle, store, and monitor all drug products, and obtain reasonable assurance of compliance CSPs, and related supplies and equipment in therewith from transporters. Compounding person- the home, including all special requirements nel shall periodically review the delivery perform- related to same. ance of couriers to ascertain that CSPs are being 4. Visually inspect all drug products, CSPs, de- efficiently and properly transported. vices, and other items the patient or caregiver is required to use immediately prior to admin- Storage in Locations Outside Compounding istration in a manner to ensure that all items Facilities are acceptable for use. For example, CSPs must be free from leakage, container cracks, Compounding facilities that ship CSPs to pa- particulates, precipitate, haziness, discolora- tients and other recipients outside their own prem- tion, or other deviations from the normal ex- ises shall ascertain or provide, whichever is appro- pected appearance, and the immediate pack- priate, the following assurances: ages of sterile devices must be completely 1. Labels and accessory labeling for CSPs in- sealed, with no evidence of loss of package clude clearly readable BUDs, storage instruc- integrity. tions, and disposal instructions for out-of-date 5. Check labels immediately prior to administra- units. tion to ensure the right drug, dose, patient, 2. Each patient or other recipient is able to store and time of administration. the CSPs properly, including the use of a 6. Clean the in-home preparation area, scrub properly functioning refrigerator and freezer hands, use proper aseptic technique, and man- if CSPs are labeled for such storage. ipulate all containers, equipment, apparatus, devices, and supplies used in conjunction with PATIENT OR CAREGIVER TRAINING administration. A formal training program is provided as a 7. Employ all techniques and precautions associ- means to ensure understanding and compliance ated with CSP administration; for example, with the many special and complex responsibilities preparing supplies and equipment, handling placed on the patient or caregiver for the storage, of devices, priming the tubing, and discontin- handling, and administration of CSPs. The instruc- uing an infusion. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 46 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin 8. Care for catheters, change dressings, and PATIENT MONITORING AND ADVERSE maintain site patency as indicated. EVENTS REPORTING 9. Monitor for and detect occurrences of thera- Compounding facilities shall clinically monitor peutic complications such as infection, phle- patients treated with CSPs according to the regu- bitis, electrolyte imbalance, and catheter lations and guidelines of their respective state misplacement. healthcare practitioner licensure boards or of ac- 10. Respond immediately to emergency or critical cepted standards of practice. Compounding facili- situations such as catheter breakage or dis- ties shall provide patients and other recipients of placement, tubing disconnection, clot forma- CSPs with a way to address their questions and re- tion, flow blockage, and equipment port any concerns that they may have with CSPs malfunction. and their administration devices. 11. Know when to seek and how to obtain profes- The SOP manuals of compounding facilities sional emergency services or professional shall describe specific instructions for receiving, advice. acknowledging, and dating receipts, and for re- 12. Handle, contain, and dispose of wastes, such cording, or filing, and evaluating reports of ad- as needles, syringes, devices, biohazardous verse events and of the quality of preparation spills or residuals, and infectious substances. claimed to be associated with CSPs. Reports of ad- Training programs include a hands-on demon- verse events with CSPs shall be reviewed stration and practice with actual items that the pa- promptly and thoroughly by compounding super- tient or caregiver is expected to use, such as CSP visors to correct and prevent future occurrences. containers, devices, and equipment. The patient or Compounding personnel are encouraged to partici- caregiver practices aseptic and injection technique pate in adverse event reporting and product defects under the direct observation of a health programs of the FDA and USP. professional. The compounding facility, in conjunction with QUALITY ASSURANCE (QA) PROGRAM nursing or medical personnel, is responsible for A provider of CSPs shall have in place a formal ensuring initially and on an ongoing basis that the QA program intended to provide a mechanism for patient or caregiver understands, has mastered, and monitoring, evaluating, correcting, and improving is capable of and willing to comply with all of the activities and processes described in this chap- these home care responsibilities. This is achieved ter. Emphasis in the QA program is placed on through a formal, written assessment program. All maintaining and improving the quality of systems specified competencies in the patient or caregiver and the provision of patient care. In addition, the training program are formally assessed. The pa- QA program ensures that any plan aimed at cor- tient or caregiver is expected to demonstrate to ap- recting identified problems also includes appropri- propriate healthcare personnel mastery of assigned ate follow-up to make certain that effective correc- activities before being allowed to administer CSPs tive actions were performed. 13 unsupervised by a health professional. Characteristics of a QA program include the Printed material such as checklists or instruc- following: tions provided during training may serve as contin- 1. Formalization in writing; uing post-training reinforcement of learning or as 2. Consideration of all aspects of the prepara- reminders of specific patient or caregiver responsi- tions and dispensing of products as described bilities. Post-training verbal counseling can also be used periodically, as appropriate, to reinforce 13 The use of additional resources, such as the Accreditation Manual for Home Care from the J oint Commission on Accreditation of training and to ensure continuing correct and com- Healthcare Organizations, may prove helpful in the development of plete fulfillment of responsibilities. a QA plan. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 47 in this chapter, including environmental test- 6. Delineation of the individuals responsible for ing and verification results; each aspect of the QA program. 3. Description of specific monitoring and evalu- In developing a specific plan, focus is on estab- ation activities; lishing objective, measurable indicators for moni- 4. Specification of how results are to be reported toring activities and processes that are deemed and evaluated; high risk, high volume, or problem prone. In gen- 5. Identification of appropriate follow-up mech- eral, the selection of indicators and the effective- anisms when action limits or thresholds are ness of the overall QA program is reassessed on an exceeded; and annual basis. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 48 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin ABBREVIATIONS AND ACRONYMS ACD automated compounding device ACPH air changes per hour ALARA as low as reasonably achievable ASHRAE American Society of Heating, Refrigerating and Air-Conditioning Engineers BI biological indicator BSC biological safety cabinet BUD beyond-use date CACI compounding aseptic containment isolator CAI compounding aseptic isolator CDC Centers for Disease Control and Prevention CETA Controlled Environment Testing Associa- tion cfu colony-forming unit(s) CSP compounded sterile preparation CSTD closed-system vial-transfer device DCA direct compounding area ECV endotoxin challenge vial EU Endotoxin Unit FDA Food and Drug Administration HEPA high efficiency particulate air HICPAC Healthcare Infection Control Practices Ad- visory Committee HVAC heating, ventilation, and air conditioning IPA isopropyl alcohol ISO International Organization for Standardiza- tion LAFW laminar airflow workbench MDVs multiple-dose vials MMWR Morbidity and Mortality Weekly Report NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Tech- nology PEC primary engineering control PET positron emission tomography PPE personnel protective equipment psi pounds per square inch QA quality assurance SOP standard operating procedure SVI sterile vial for injection TSA trypticase soy agar USP United States Pharmacopeia Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 49 APPENDICES Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 NOTEThis tabular appendix selectively abstracts and condenses the full text of 797 for rapid reference only. Compounding personnel are responsible for reading, understanding and complying with the full text and all official USP terminology, content, and conditions therein. INTRODUCTION Chapter purpose is to prevent harm and death to patients treated with CSPs. Chapter pertains to preparation, storage, and transportation, but not administration, of CSPs. Personnel and facilities to which 797 applies; therefore, for whom and which it may be enforced by regulatory and accreditation authorities. Types of preparations designated to be CSPs according to their physical forms, and their sites and routes of administration to patients. Compounding personnel must be meticulously conscientious to preclude contact contamination of CSPs both within and outside ISO Class 5 areas. ORGANIZATION All compounding personnel shall be responsible for understanding fundamental practices and precautions within USP 797, for developing and implementing appropriate procedures, and for continually evaluating these procedures and the quality of final CSPs to prevent harm. DEFINITIONS Twenty-eight terms are defined and integral to complying with USP 797. RESPONSIBILITY OF COMPOUNDING PERSONNEL Practices and quality assurances required to prepare, store, and transport CSPs that are sterile, and acceptably accurate, pure, and stable. CSP MICROBIAL CONTAMINATION RISK LEVELS Proper training and evaluation of personnel, proper cleansing and garbing of personnel, proper cleaning and disinfecting of compounding work environments, and proper maintenance and monitoring of controlled environmental locations (all of which are detailed in their respective sections). Low-Risk Level CSPs Aseptic manipulations within an ISO Class 5 environment using three or fewer sterile products and entries into any container. In absence of passing sterility test, store not more than 48 hours at controlled room temperature, 14 days at cold temperature, and 45 days in solid frozen state at 25 to 10 or colder. Media-fill test at least annually by compounding personnel. Low-Risk Level CSPs with 12-Hour or Less BUD Fully comply with all four specific criteria. Sinks should not be located adjacent to the ISO Class 5 primary engineering control. Sinks should be separated from the immediate area of the ISO Class 5 primary engineering control device. Medium-Risk Level CSPs Aseptic manipulations within an ISO Class 5 environment using prolonged and complex mixing and transfer, more than three sterile products and entries into any container, and pooling ingredients from multiple sterile products to prepare multiple CSPs. In absence of passing sterility test, store not more than 30 hours at controlled room temperature, 9 days at cold temperature, and 45 days in solid frozen state at 25 to 10 or colder. Media-fill test at least annually by compounding personnel. High-Risk Level CSPs Confirmed presence of nonsterile ingredients and devices, or confirmed or suspected exposure of sterile ingredients for more than one hour to air quality inferior to ISO Class 5 before final sterilization. Sterilization method verified to achieve sterility for the quantity and type of containers. Meet allowable limits for bacterial endotoxins. Maintain acceptable strength and purity of ingredients and integrity of containers after sterilization. In absence of passing sterility test, store not more than 24 hours at controlled room temperature, 3 days at cold temperature, and 45 days in solid frozen state at 25 to 10 or colder. Media-fill test at least semiannually by compounding personnel. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 50 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 PERSONNEL TRAINING AND EVALUATION IN ASEPTIC MANIPULATIONS SKILLS Pass didactic, practical skill assessment and media-fill testing initially, followed by an annual assessment for a low- and medium-risk level compounding and semi-annual assessment for high-risk level compounding. Compounding personnel who fail written tests, or whose media-fill test vials result in gross microbial colonization, shall be immediately reinstructed and re-evaluated by expert compounding personnel to ensure correction of all aseptic practice deficiencies. IMMEDIATE-USE CSPs Fully comply with all six specified criteria. SINGLE-DOSE AND MULTIPLE-DOSE CONTAINERS Beyond-use date 28 days, unless specified otherwise by the manufacturer, for closure sealed multiple-dose containers after initial opening or entry. Beyond-use time of 6 hours, unless specified otherwise by the manufacturer, for closure sealed single-dose containers in ISO Class 5 or cleaner air after initial opening or entry. Beyond-use time of 1 hour for closure sealed single-dose containers after being opened or entered in worse than ISO Class 5 air. Storage of opened single-dose ampuls is not permitted. HAZARDOUS DRUGS AS CSPs Appropriate personnel protective equipment. Appropriate primary engineering controls (BSCs and CACIs) are used for concurrent personnel protection and exposure of critical sites. Hazardous drugs shall be stored separately from other inventory in a manner to prevent contamination and personnel exposure. At least 0.01 inch water column negative pressure and 12 air changes per hour in non-cleanrooms in which CACIs are located. Hazardous drugs shall be handled with caution at all times using appropriate chemotherapy gloves during receiving, distribution, stocking, inventorying, preparing for administration, and disposal. Hazardous drugs shall be prepared in an ISO Class 5 environment with protective engineering controls in place, and following aseptic practices specified for the appropriate contamination risk levels. Access to drug preparation areas shall be limited to authorized personnel. A pressure indicator shall be installed that can readily monitor room pressurization, which is documented daily. Annual documentation of full training of personnel regarding storage, handling, and disposal of hazardous drugs. When used, a CSTD shall be used in an ISO Class 5 primary engineering control device. At least 0.01 inch water column negative pressure is required for compounding of hazardous drugs. Negative-pressure buffer area is not required for low-volume compounding operations when CSTD is used in BSC or CACI. Compounding personnel of reproductive capability shall confirm in writing that they understand the risks of handling hazardous drugs. Disposal of all hazardous drug wastes shall comply with all applicable federal and state regulations. Total external exhaust of primary engineering controls. Assay of surface wipe samples every 6 months. RADIOPHARMACEUTICALS AS CSPs Positron Emission Tomography is according to USP chapter 823. Appropriate primary engineering controls and radioactivity containment and shielding. Radiopharmaceuticals compounded from sterile components, in closed sterile containers, with volume of 100 mL or less for a single- dose injection or not more than 30 mL taken from a multiple-dose container shall be designated as and conform to the standards for low-risk level CSPs. Radiopharmaceutical vials, designed for multi-use, compounded with technetium-99m, exposed to ISO Class 5 environment and punctured by needles with no direct contact contamination may be used up to the time indicated by manufacturers recommendations. Location of primary engineering controls permitted in ISO Class 8 controlled environment. Technetium-99m/Molybdenum-99 generators used according to manufacturer, state, and federal requirements. Radiopharmaceuticals prepared as low-risk level CSPs with 12-hour or less BUD shall be prepared in a segregated compounding area. Materials and garb exposed in patient-care and treatment area shall not cross a line of demarcation into the segregated compounding area. Technetium-99m/Molybdenum-99 generators must be eluted in ISO Class 8 conditions. Segregated compounding area will be designated with a line of demarcation Storage and transport of properly shielded vials of radiopharmaceutical CSPs may occur in a limited access ambient environment without a specific ISO class designation. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 51 Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 ALLERGEN EXTRACTS AS CSPs Allergen extracts as CSPs are not subject to the personnel, environmental, and storage requirements for all CSP Microbial Contamination Risk Levels when certain criteria are met. VERIFICATION OF COMPOUNDING ACCURACY AND STERILITY Review labels and document correct measurements, aseptic manipulations, and sterilization procedures to confirm correct identity, purity, and strength of ingredients in, and sterility of, CSPs. Assay finished CSPs to confirm correct identity and, or, strength of ingredients. Sterility test finished CSPs. Sterilization Methods Verify that methods achieve sterility while maintaining appropriate strength, purity, quality, and packaging integrity. Prove effectiveness by USP chapter 71, equivalent, or superior sterility testing. Sterilization of High-Risk Level CSPs by Filtration Nominal 0.2-m pore size sterile membranes that are chemically and physically compatible with the CSP. Complete rapidly without filter replacement. Subject filter to manufacturers recommended integrity test (e.g., bubble point test) after filtering CSPs. Sterilization of High-Risk Level CSPs by Steam Test to verify the mass of containers to be sterilized will be sterile after the selected exposure duration in the particular autoclave. Ensure live steam contacts all ingredients and surfaces to be sterilized. Pass solutions through a 1.2-m or smaller nominal pore size filter into final containers to remove particulates before sterilization. Heated filtered air shall be evenly distributed throughout the chamber by a blower device. Dry heat shall only be used for those materials that cannot be sterilized by steam, when the moisture would either damage or be impermeable to the materials. Sufficient space shall be left between materials to allow for good circulation of the hot air. The description of dry heat sterilization conditions and duration for specific CSPs shall be included in written documentation in the compounding facility. The effectiveness of dry heat sterilization shall be verified using appropriate biological indicators and other confirmation. The oven should be equipped with a system for controlling temperature and exposure period. Depyrogenation by Dry Heat Dry heat depyrogenation shall be used to render glassware or containers, such as vials free from pyrogens as well as viable microbes. The description of the dry heat depyrogenation cycle and duration for specific load items shall be included in written documentation in the compounding facility. The effectiveness of the dry heat depyrogenation cycle shall be verified using endotoxin challenge vials (ECVs). The bacterial endotoxin test should be performed on the ECVs to verify the cycle is capable of achieving a 3 log reduction in endotoxin. ENVIRONMENTAL QUALITY AND CONTROL Exposure of Critical Sites ISO Class 5 or better air. Preclude direct contact (e.g., touch and secretions) contamination. ISO Class 5 Air Sources, Buffer Areas, and Ante-Areas A buffer area is an area that provides at least ISO Class 7 air quality. New representations of facility layouts. Each compounding facility shall ensure that each source of ISO Class 5 environment for exposure of critical sites and sterilization by filtration is properly located, operated, maintained, monitored, and verified. Placement of devices (e.g., computers and printers) and objects (e.g., carts and cabinets) can be placed in buffer areas and shall be verified by testing or monitoring. Viable and Nonviable Environmental Sampling (ES) Testing Environmental sampling shall occur as part a comprehensive quality management program and shall occur minimally when several conditions exist. The ES program should provide information to staff and leadership to demonstrate that the engineering controls are maintaining an environment within the compounding area that consistently maintains acceptably low viable and nonviable particle levels. Environmental Nonviable Particle Testing Program Certification and testing of primary (LAFWs, BSCs, CAIs and CACIs) and secondary engineering controls (buffer and ante areas) shall be performed by a qualified individual no less than every six months and whenever the device or room is relocated, altered, or major service to the facility is performed. Certification procedures such as those outlined in the CETA Certification Guide for Sterile Compounding Facilities (CAG-003-2006) shall be used. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 52 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 Total Particle Counts Certification that each ISO classified area (e.g., ISO Class 5, 7 and 8) is within established guidelines shall be performed no less than every 6 months and whenever the LAFW, BSC, CAI, or CACI is relocated or the physical structure of the buffer room or ante-area has been altered. Testing shall be performed by qualified operators using current, state-of-the-art electronic equipment with results meeting ISO Class 5, 7, or 8 depending on the requirements of the area. All certification records shall be maintained and reviewed by supervising personnel or other designated employee to ensure that the controlled environments comply with the proper air cleanliness, room pressures, and air changes per hour. Pressure Differential Monitoring A pressure gauge or velocity meter shall be installed to monitor the pressure differential or airflow between the buffer area and ante- area and the ante-area and the general environment outside the compounding area. The results shall be reviewed and documented on a log at least every work shift (minimum frequency shall be at least daily) or by a continuous recording device. The pressure between the ISO Class 7 and general pharmacy area shall not be less than 5 Pa (0.02 inch water column (w.c.). In facilities where low- and medium-risk level CSPs are prepared, differential airflow shall maintain a minimum velocity of 0.2 meter/second (40 fpm) between buffer area and ante-area. Environmental Viable Airborne Particle Testing ProgramSampling Plan An appropriate environmental sampling plan shall be developed for airborne viable particles based on a risk assessment of compounding activities performed. Selected sampling sites shall include locations within each ISO Class 5 environment and in the ISO Class 7 and 8 areas, and the segregated compounding areas at greatest risk of contamination (e.g., work areas near the ISO Class 5 environment, counters near doors, pass-through boxes). The plan shall include sample location, method of collection, frequency of sampling, volume of air sampled, and time of day as related to activity in the compounding area and action levels. It is recommended that compounding personnel refer to USP Chapter Microbiological Evaluation of Clean Rooms and Other Controlled Environments 1116 and the CDC Guidelines for Environmental Infection Control in Healthcare Facilities-2003 for more information. Growth Media A general microbiological growth medium such as SoybeanCasein Digest Medium (also known as trypticase soy broth (TSB) or agar (TSA)) shall be used to support the growth of bacteria. Malt extract agar (MEA) or some other media that supports the growth of fungi shall be used in high-risk level compounding environments. Media used for surface sampling shall be supplemented with additives to neutralize the effects of disinfecting agents (e.g., TSA with lecithin and polysorbate 80). Viable Air Sampling Evaluation of airborne microorganisms using volumetric collection methods in the controlled air environments shall be performed by properly trained individuals for all compounding risk levels. Impaction shall be the preferred method of volumetric air sampling. For low-, medium-, and high-risk level compounding, air sampling shall be performed at locations that are prone to contamination during compounding activities and during other activities like staging, labeling, gowning, and cleaning. Locations shall include zones of air backwash turbulence within laminar airflow workbench and other areas where air backwash turbulence may enter the compounding area. For low-risk level CSPs with 12-hour or less BUD, air sampling shall be performed at locations inside the ISO Class 5 environment and other areas that are in close proximity to the ISO class 5 environment, during the certification of the primary engineering control. Consideration should be given to the overall effect the chosen sampling method will have on the unidirectional airflow within a compounding environment. Air Sampling Devices The instructions in the manufacturers user manual for verification and use of electric air samplers that actively collect volumes of air for evaluation shall be followed. A sufficient volume of air (4001000 liters) shall be tested at each location in order to maximize sensitivity. It is recommended that compounding personnel also refer to USP Chapter 1116 that can provide more information on the use of volumetric air samplers and volume of air that should be sampled to detect environmental bioburden excursions. Air Sampling Frequency and Process Air sampling shall be performed at least semiannually (i.e. every 6 months), as part of the re-certification of facilities and equipment for area where primary engineering controls are located. A sufficient volume of air shall be sampled and the manufacturers guidelines for use of the electronic air sampling equipment followed. Any facility construction or equipment servicing may require the need to perform air sampling during these events. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 53 Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 Incubation Period The microbial growth media plates used to collect environmental sampling are recovered, covers secured (e.g., taped), inverted, and incubated at a temperature and for a time period conducive to multiplication of microorganisms. The number of discrete colonies of microorganisms shall be counted and reported as colony-forming units (cfu) and documented on an environmental monitoring form. Counts from air monitoring need to be transformed into cfu/cubic meter of air and evaluated for adverse trends. TSA should be incubated at 35 2 for 23 days. MEA or other suitable fungal media should be incubated at 28 2 for 57 days. Action Levels, Documentation and Data Evaluation Sampling data shall be collected and reviewed on a periodic basis as a means of evaluating the overall control of the compounding environment. Competent microbiology personnel shall be consulted if an environmental sampling consistently shows elevated levels of microbial growth. An investigation into the source of the environmental contamination shall be conducted. Any cfu count that exceeds its respective action level should prompt a re-evaluation of the adequacy of personnel work practices, cleaning procedures, operational procedures, and air filtration efficiency within the aseptic compounding location. Table titled, Recommended Action Levels for Microbial Contamination should only be used as a guideline Facility Design and Environmental Controls Compounding facilities are physically designed and environmentally controlled to minimize airborne contamination from contacting critical sites. Compounding facilities shall provide a comfortable and well-lighted working environment, which typically includes a temperature of 20 or cooler to maintain comfortable conditions for compounding personnel when attired in the required aseptic compounding garb. Primary engineering controls provide unidirectional (i.e., laminar) HEPA air at a velocity sufficient to prevent airborne particles from contacting critical sites. In situ air pattern analysis via smoke studies shall be conducted at the critical area to demonstrate unidirectional airflow and sweeping action over and away from the product under dynamic conditions. Policies and procedures for maintaining and working within the primary engineering control area shall be written and followed. The policies and procedures will be determined by the scope and risk levels of the aseptic compounding activities used during the preparation of the CSPs. The principles of HEPA-filtered unidirectional airflow in the work environment shall be understood and practiced in the compounding process in order to achieve the desired environmental conditions. Clean rooms for nonhazardous and nonradioactive CSPs are supplied with HEPA that enters from ceilings with return vents low on walls, and provide not less than 30 air changes per hour. Buffer areas maintain 0.02- to 0.05-inch water column positive pressure, and do not contain sinks or drains. Air velocity from buffer rooms or zones to ante-areas is at least 40 feet/minute. The primary engineering controls shall be placed within a buffer area in such a manner as to avoid conditions that could adversely affect their operation. The primary engineering controls shall be placed out of the traffic flow and in a manner to avoid disruption from the HVAC system and room cross-drafts. HEPA-filtered supply air shall be introduced at the ceiling. All HEPA filters shall be efficiency tested using the most penetrating particle size and shall be leak tested at the factory and then leak tested again in situ after installation. Activities and tasks carried out within the buffer area shall be limited to only those necessary when working within a controlled environment. Only the furniture, equipment, supplies, and other material required for the compounding activities to be performed shall be brought into the room. Surfaces and essential furniture in buffer rooms or zones and clean rooms shall be nonporous, smooth, nonshedding, impermeable, cleanable, and resistant to disinfectants. The surfaces of ceilings, walls, floors, fixtures, shelving, counters, and cabinets in the buffer area shall be smooth, impervious, free from cracks and crevices, and nonshedding, thereby promoting cleanability and minimizing spaces in which microorganisms and other contaminants may accumulate. The surfaces shall be resistant to damage by disinfectant agents. J unctures of ceilings to walls shall be coved or caulked to avoid cracks and crevices where dirt can accumulate. Ceiling tiles shall be caulked around each perimeter to seal them to the support frame. The exterior lens surface of ceiling lighting fixtures shall be smooth, mounted flush, and sealed. Any other penetrations through the ceiling or walls shall be sealed. The buffer area shall not contain sources of water (sinks) or floor drains. Work surfaces shall be constructed of smooth, impervious materials, such as stainless steel or molded plastic, so that they are easily cleaned and disinfected. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 54 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 (Continued) Carts shall be of stainless steel wire, nonporous plastic, or sheet metal construction with good quality, cleanable casters to promote mobility. Storage shelving, counters, and cabinets shall be smooth, impervious, free from cracks and crevices, nonshedding, cleanable, and disinfectable. Their number, design, and manner of installation the itmes above shall promote effective cleaning and disinfection. If ceilings consist of inlaid panels, the panels should be impregnated with a polymer to render them impervious and hydrophobic. Dust-collecting overhangs, such as ceiling utility pipes, or ledges, such as windowsills, should be avoided. Air returns should be mounted low on the wall creating a general top-down dilution of room air with HEPA-filtered make-up air. Placement Of Primary Engineering Controls Within Iso Class 7 Buffer Areas Primary engineering controls for nonhazardous and nonradioactive CSPs are located in buffer areas, except for CAIs that are proven to maintain ISO Class 5 air when particle counts are sampled 6 to 12 inches upstream of critical site exposure areas during performance of normal inward and outward transfer of materials, and compounding manipulations when such CAIs are located in air quality worse than ISO Class 7. Presterilization procedures for high-risk level CSPs, such as weighing and mixing, shall be completed in no worse than an ISO Class 8 environment. Primary engineering controls shall be located out of traffic patterns and away from room air currents that could disrupt the intended airflow patterns. When isolators are used for sterile compounding, the recovery time to achieve ISO Class 5 air quality shall be documented and internal procedures developed to ensure that adequate recovery time is allowed after material transfer before and during compounding operations. When compounding activities require the manipulation of a patients blood-derived or other biological material (e.g., radiolabeling a patients or a donors white blood cells), the manipulations shall be clearly separated from routine material-handling procedures and equipment used in CSP preparation activities, and they shall be controlled by specific standard operating procedures in order to avoid any cross-contamination. Food, drinks, and items exposed in patient care areas, and unpacking of bulk supplies and personnel cleansing and garbing are prohibited from buffer areas or rooms. Demarcation designation between buffer areas or rooms and ante-areas. Antiseptic hand cleansing and sterile gloves in buffer areas or rooms. Packaged compounding supplies and components, such as needles, syringes, tubing sets, and small- and large-volume parenterals, should be uncartoned and wiped down with a disinfectant that does not leave a residue (e.g., sterile 70% IPA) when possible in an ante-area, of ISO Class 8 air quality, before being passed into the buffer areas. Cleaning and Disinfecting the Sterile Compounding Areas Trained personnel write detailed procedures including cleansers, disinfectants, and non-shedding wipe and mop materials. Cleaning and disinfecting surfaces in the LAFWs, BSCs, CAIs, and CACIs shall be cleaned and disinfected frequently including at the beginning of each work shift, before each batch preparation is started, every 30 minutes during continuous compounding periods of individual CSPs, when there are spills, and when surface contamination is known or suspected from procedural breaches. Trained compounding personnel are responsible for developing, implementing, and practicing the procedures for cleaning and disinfecting the DCAs written in the SOPs. Cleaning and disinfecting shall occur before compounding is performed. Items shall be removed from all areas to be cleaned and surfaces shall be cleaned by removing loose material and residue from spills, e.g., water-soluble solid residues are removed with Sterile Water (for Injection or Irrigation) and low-shedding wipes. This shall be followed by wiping with a residue-free disinfecting agent, such as sterile 70% IPA, which is allowed to dry before compounding begins. Work surfaces in ISO Class 7 and 8 areas and segregated compounding areas are cleaned at least daily. Dust and debris shall be removed when necessary from storage sites for compounding ingredients and supplies, using a method that does not degrade the ISO Class 7 or 8 air quality. Floors in ISO Class 7 and 8 areas are cleaned daily when no compounding occurs. IPA (70% isopropyl alcohol) remains on surfaces to be disinfected for at least 30 seconds before such are used to prepare CSPs. Emptied shelving, walls, and ceilings in ante-areas are cleaned and disinfected at least monthly. Mopping shall be performed by trained personnel using approved agents and procedures described in the written SOPs. Cleaning and disinfecting agents, their schedules of use and methods of application shall be in accordance with written SOPs and followed by custodial and/or compounding personnel. All cleaning materials, such as wipers, sponges, and mops, shall be nonshedding, preferably composed of synthetic micro fibers, and dedicated to use in the buffer area, or ante-area, and segregated compounding areas and shall not be removed from these areas except for disposal. If cleaning materials are reused (e.g., mops), procedures shall be developed (based on manufacturer recommendations) that ensure that the effectiveness of the cleaning device is maintained and repeated use does not add to the bioburden of the area being cleaned. Supplies and equipment removed from shipping cartons shall be wiped with a suitable disinfecting agent (e.g., sterile 70% IPA) delivered from a spray bottle or other suitable delivery method. After the disinfectant is sprayed or wiped on a surface to be disinfected, the disinfectant shall be allowed to dry, and during this time the item shall not be used for compounding purposes. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 55 Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 (Continued) Sterile 70% IPA wetted gauze pads or other particle-generating material shall not be used to disinfect the sterile entry points of packages and devices. Personnel Cleansing And Garbing Personnel shall also be thoroughly competent and highly motivated to perform flawless aseptic manipulations with ingredients, devices, and components of CSPs. Personnel with rashes, sunburn, weeping sores, conjunctivitis, active respiratory infection, and cosmetics are prohibited from preparing CSPs. Compounding personnel remove personal outer garments; cosmetics; artificial nails; hand, wrist, and body jewelry that can interfere with the fit of gowns and gloves; and visible body piercing above the neck. Order of compounding garb and cleansing in ante-area: shoes or shoe covers, head and facial hair covers, face mask, fingernail cleansing, hand and forearm washing and drying; non-shedding gown. Order of cleansing and gloving in buffer room or area: hand cleansing with a persistently active alcohol-based product with persistent activity, allow hands to dry; don sterile gloves. Routinely disinfect gloves with sterile 70% IPA after contacting nonsterile objects. Inspect gloves for holes and replace when breaches are detected. Personnel repeat proper procedures after they are exposed to direct contact contamination or worse than ISO Class 8 air. These requirements are exempted only for immediate use CSPs and CAIs for which manufacturers provide written documentation based on validated testing that such personnel practices are not required to maintain sterility in CSPs. Personnel Training And Competency Evaluation Of Garbing, Aseptic Work Practices And Cleaning/Disinfection Procedures Personnel who prepare CSPs shall be trained conscientiously and skillfully by expert personnel, multi-media instructional sources, and professional publications in the theoretical principles and practical skills of garbing procedures, aseptic work practices, achieving and maintaining ISO Class 5 environmental conditions, and cleaning and disinfection procedures. This training shall be completed and documented before any compounding personnel begin to prepare CSPs. Compounding personnel shall complete didactic training, pass written competence assessments, undergo skill assessment using observational audit tools, and media-fill testing. Media-fill testing of aseptic work skills shall be performed initially before beginning to prepare CSPs and at least annually thereafter for low- and medium-risk level compounding; and semiannually for high-risk level compounding. Compounding personnel who fail written tests, observational audits, or whose media-fill test vials have one or more units showing visible microbial contamination, shall be reinstructed and re-evaluated by expert compounding personnel to ensure correction of all aseptic work practice deficiencies. Compounding personnel shall pass all evaluations prior to resuming compounding of sterile preparations. Compounding personnel must demonstrate proficiency of proper hand hygiene, garbing, and consistent cleaning procedures in addition to didactic evaluation and aseptic media fill. Cleaning and disinfecting procedures performed by other support personnel shall be thoroughly trained in proper hand hygiene, and garbing, cleaning, and disinfection procedures by a qualified aseptic compounding expert. Support personnel shall routinely undergo performance evaluation of proper hand hygiene, garbing, and all applicable cleaning and disinfecting procedures conducted by a qualified aseptic compounding expert. Competency Evaluation of Garbing and Aseptic Work Practices Compounding personnel shall be evaluated initially prior to beginning compounding CSPs and whenever an aseptic media fill is performed using a Sample Form for Assessing Hand Hygiene and Garbing Related Practices of Compounding Personnel and the personnel glove fingertip sampling procedures Aseptic Work Practice Assessment and Evaluation via Personnel Glove Fingertip Sampling Monitoring of compounding personnel glove finger tips shall be performed for all CSP risk level compounding. Glove fingertip sampling shall be used to evaluate the competency of personnel in performing hand hygiene and garbing procedures in addition to educating compounding personnel on proper work practices. All personnel shall demonstrate competency in proper hand hygiene and garbing procedures in addition to aseptic work practices. Sterile contact agar plates shall be used to sample the gloved fingertips of compounding personnel after garbing to assess garbing competency and after completing the media-fill preparation. Gloves shall not be disinfected with sterile 70% IPA immediately prior to sampling. Garbing and Gloving Competency Evaluation Compounding personnel shall be visually observed during the process of performing hand hygiene and garbing procedures. The visual observation shall be documented on a Sample Form for Assessing Hand Hygiene and Garbing Related Practices of Compounding Personnel and maintained to provide a permanent record of and long-term assessment of personnel competency. Gloved Fingertip Sampling Immediately after the compounder completes the hand hygiene and garbing procedure, the evaluator shall collect a gloved fingertip and thumb sample from both hands of the compounder onto appropriate agar plates by lightly pressing each finger tip into the agar. The plates shall be incubated for the appropriate incubation period and at the appropriate temperature. All employees shall successfully complete an initial competency evaluation and gloved fingertip/thumb sampling procedure (0 cfu) no less than three times before initially being allowed to compound CSPs for human use. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 56 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 (Continued) After completing the initial gowning and gloving competency evaluation, re-evaluation of all compounding personnel shall occur at least annually for low- and medium-risk level CSPs and semiannually for high-risk level CSPs before being allowed to continue compounding CSPs. Gloves shall not be disinfected with sterile 70% IPA prior to testing. The sampled gloves shall be immediately discarded and proper hand hygiene performed after sampling. The nutrient agar plates shall be incubated as stated below. The cfu action level for gloved hands shall be based on the total number of cfu on both gloves and not per hand. Results should be reported separately as number of cfu per employee per hand (left hand, right hand). Incubation Period At the end of the designated sampling period, the agar plates are recovered, covers secured, inverted and incubated at a temperature and for a time period conducive to multiplication of microorganisms. Trypticase soy agar (TSA) with lecithin and polysorbate 80 shall be incubated at 35 2 for 23 days. Aseptic Manipulation Competency Evaluation All compounding personnel shall have their aseptic technique and related practice competency evaluated initially during the media-fill test procedure and subsequent annual or semiannual media-fill test procedures on the Sample Form for Assessing Aseptic Technique and Related Practices of Compounding Personnel. Media-Fill Test Procedure The skill of personnel to aseptically prepare CSPs shall be evaluated using sterile fluid bacterial culture media-fill verification. Media-filled vials shall be incubated within a range of 35 2 for 14 days. Surface Cleaning and Disinfection Sampling and Assessment Surface sampling shall be performed in all ISO classified areas on a periodic basis and can be accomplished using contact plates and/or swabs and shall be done at the conclusion of compounding Locations to be sampled shall be defined in a sample plan or on a form. Cleaning and Disinfecting Competency Evaluation Compounding personnel and other personnel responsible for cleaning shall be visually observed during the process of performing cleaning and disinfecting procedures during initial personnel training on cleaning procedures, changes in cleaning staff and at the completion of any Media-Fill Test Procedure. Visual observation shall be documented on a Sample Form for Assessing Cleaning and Disinfection Procedures and maintained to provide a permanent record of, and long-term assessment of, personnel competency. Surface Collection Methods Immediately after sampling a surface with the contact plate, the sampled area shall be thoroughly wiped with a non-shedding wipe soaked in sterile 70% IPA. Results should be reported as cfu per unit of surface area. Action Levels, Documentation, and Data Evaluation Environmental sampling data shall be collected and reviewed on a routine basis as a means of evaluating the overall control of the compounding environment. If an activity consistently shows elevated levels of microbial growth, competent microbiology personnel shall be consulted. An investigation into the source of the contamination shall be conducted. When gloved fingertip sample results exceeds action levels after proper incubation, a review of hand hygiene and garbing procedures as well as glove and surface disinfection procedures and work practices shall be performed and documented. Any cfu count that exceeds its respective action level should prompt a re-evaluation of the adequacy of personnel work practices, cleaning procedures, operational procedures, and air filtration efficiency within the aseptic compounding location. SUGGESTED STANDARD OPERATING PROCEDURES All facilities are required to have these, and they must include at least the items enumerated in this section. FINISHED PREPARATION RELEASE CHECKS AND TESTS Inspection of Solution Dosage Forms and Review of Compounding Procedures Review procedures and documents to ensure sterility, purity, correct identities and amounts of ingredients, and stability. Visually inspect for abnormal particulate matter and color, and intact containers and seals. Sterility Testing High-risk level CSPs prepared in batches of more than 25 identical containers, or exposed longer than 12 hours at 2 to 8 and 6 hours at warmer than 8 before being sterilized. Bacterial Endotoxin (Pyrogen) Testing High-risk level CSPs, excluding those for inhalation and ophthalmic administration, prepared in batches of more than 25 identical containers, or exposed longer than 12 hours at 2 to 8 and 6 hours at warmer than 8 before being sterilized. Identity and Strength Verification of Ingredients Written procedures to verify correct identity, quality, amounts, and purities of ingredients used in CSPs. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 57 Appendix I. Principal Competencies, Conditions, Practices, and Quality Assurances That Are Required ( shall) and Recommended ( should) in USP Chapter 797 (Continued) Written procedures to ensure labels of CSPs contain correct names and amounts or concentrations of ingredients, total volumes, beyond-use dates, storage conditions, and route(s) of administration. STORAGE AND BEYOND-USE DATING Determining Beyond-Use Dates Use the general criteria in USP 795 in the absence of direct stability-indicating assays or authoritative literature that supports longer durations. MAINTAINING STERILITY, PURITY, AND STABILITY OF DISPENSED AND DISTRIBUTED CSPs Written procedures for proper packaging, storage, and transportation conditions to maintain sterility, quality, purity, and strength of CSPs. Redispensed CSPs When sterility, and acceptable purity, strength, and quality can be ensured. Assignment of sterility storage times and stability beyond-use dates that occur later than those of originally dispensed CSPs must be based on results of sterility testing and quantitative assay of ingredients. Packaging And Transporting CSPs Packaging maintains physical integrity, sterility, stability, and purity of CSPs. Modes of transport that maintain appropriate temperatures and prevent damage to CSPs. PATIENT OR CAREGIVER TRAINING Multiple component formal training program to ensure patients and caregivers understand the proper storage, handling, use, and disposal of CSPs. PATIENT MONITORING AND ADVERSE EVENTS REPORTING Written standard procedures describe means for patients to ask questions and report concerns and adverse events with CSPs, and for compounding supervisors to correct and prevent future problems. Adverse events and defects with CSPs reported to FDAs MedWatch and USPs MEDMARX programs. Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 59 Appendix III. Sample Form for Assessing Hand Hygiene and Garbing Related Practices of Compounding Personnel Printed name and position/title of person assessed: Name of facility or location: Hand Hygiene and Garbing Practices: The qualified evaluator will mark () each space for which the person being assessed has acceptably completed the described activity, prints N/A if the activity is not applicable to the assessment session or N/O if the activity was not observed. * Presents in a clean appropriate attire and manner. Wears no cosmetics or jewelry (watches, rings, earrings, etc. piercing jewelry included) upon entry into ante-areas. Brings no food or drinks into or stored in the ante-areas or buffer areas. Is aware of the line of demarcation separating clean and dirty sides and observes required activities. Dons shoe covers or designated clean-area shoes one at a time, placing the covered or designated shoe on clean side of the line of demarcation, as appropriate. Dons beard cover if necessary. Dons head cover assuring that all hair is covered. Dons face mask to cover bridge of nose down to include chin. Performs hand hygiene procedure by wetting hands and forearms and washing using soap and warm water for at least 30 seconds. Dries hands and forearms using lint-free towel or hand dryer. Selects the appropriate sized gown examining for any holes, tears, or other defects. Dons gown and ensures full closure. Disinfects hands again using a waterless alcohol-based surgical hand scrub with persistent activity and allows hands to dry thoroughly. before donning sterile gloves Dons appropriate sized sterile gloves ensuring that there is a tight fit with no excess glove material at the fingertips. Examines gloves ensuring that there are no defects, holes, or tears. While engaging in sterile compounding activities, routinely disinfects gloves with sterile 70% IPA prior to work in the direct compounding area (DCA) and after touching items or surfaces that may contaminate gloves. Removes PPE on the clean side of the ante-area. Removes gloves and performs hand hygiene. Removes gown and discards it, or hangs it on hook if it is to be reused within the same work day. Removes and discards mask, head cover, and beard cover (if used). Removes shoe covers or shoe one at a time, ensuring that uncovered foot is placed on the dirty side of the line of demarcation and performs hand hygiene again. (Removes and discards shoe covers every time the compounding area is exited). * The person assessed is immediately informed of all unacceptable activities (i.e., spaces lacking a Check marks, N/A, or N/O) and shown and informed of specific corrections. Signature of Person Assessed Printed Name Date Signature of Qualified Evaluator Printed Name Date Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. 60 797 Pharmaceutical CompoundingSterile Preparations Revision Bulletin Appendix IV. Sample Form for Assessing Aseptic Technique and Related Practices of Compounding Personnel Printed name and position/title of person assessed: Name of facility or location: Aseptic Technique, Safety, and Quality Assurance Practices: The qualified evaluator will mark () each space for which the person being assessed has acceptably completed the described activity, prints N/A if the activity is not applicable to the assessment session or N/O if the activity was not observed. * Completes the Hand Hygiene and Garbing Competency Assessment Form. Performs proper hand hygiene, garbing, and gloving procedures according to SOPs. Disinfects ISO Class 5 device surfaces with an appropriate agent. Disinfects components/vials with an appropriate agent prior to placing into ISO Class 5 work area. Introduces only essential materials in a proper arrangement in the ISO Class 5 work area. Does not interrupt, impede, or divert flow of first-air to critical sites. Ensures syringes, needles, and tubing remain in their individual packaging and are only opened in ISO Class 5 work area Performs manipulations only in the appropriate DCA of the ISO Class 5 device. Does not expose critical sites to contact contamination or worse than ISO Class 5 air. Disinfects stoppers, injection ports, and ampul necks by wiping with sterile 70% IPA and allows sufficient time to dry. Affixes needles to syringes without contact contamination. Punctures vial stoppers and spikes infusion ports without contact contamination. Labels preparation(s) correctly. Disinfects sterile gloves routinely by wiping with sterile 70% IPA during prolonged compounding manipulations. Cleans, sets up, and calibrates automated compounding device (e.g., TPN compounder) according to manufacturers instructions. Disposes of sharps and waste according to institutional policy or recognized guidelines. * The person assessed is immediately informed of all unacceptable activities (i.e., spaces lacking a Check marks, N/A, or N/O) and shown and informed of specific corrections. Signature of Person Assessed Printed Name Date Signature of Qualified Evaluator Printed Name Date Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved. Revision Bulletin 797 Pharmaceutical CompoundingSterile Preparations 61 Appendix V. Sample Form for Assessing Cleaning and Disinfection Procedures Printed name and position/title of person assessed: Name of facility or location: Cleaning and Disinfection Practices: The qualified evaluator will mark () each space for which the person being assessed has acceptably completed the described activity, prints N/A if the activity is not applicable to the assessment session or N/O if the activity was not observed. * Daily Tasks: Prepares correct concentration of disinfectant solution according to manufacturers instructions. Uses appropriately labeled container for the type of surface to be cleaned (floor, wall, production bins, etc.). Documents disinfectant solution preparation. Follows garbing procedures when performing any cleaning activities. At the beginning of each shift, cleans all ISO Class 5 devices prior to compounding in the following order: walls, IV bar, automated compounders, and work surface. Uses a lint free wipe soaked with sterile 70% IPA or other approved disinfectant solution and allows to dry completely. Removes all compounder components and cleans all ISO Class 5 areas as stated above at the end of each shift. Cleans all counters and easily cleanable work surfaces. Mops floors, using the mop labeled floors, starting at the wall opposite the room entry door; mops floor surface in even strokes toward the operator. Moves carts as needed to clean entire floor surface. Use of a microfiber cleaning system is an acceptable alternative to mops. In the ante-area, cleans sink and all contact surfaces; cleans floor with a disinfectant solution or uses microfiber cleaning system. Monthly Tasks: Performs monthly cleaning on a designated day. Prepares a disinfectant solution as stated in daily tasks that is appropriate for the surfaces to be cleaned. Cleans buffer area and ante-area ceiling, walls, and storage shelving with a disinfectant solution and a mop or uses a microfiber cleaning system. Once ISO Class 5 area is clean, cleans compounding room ceiling, followed by walls and ending with the floor. Uses appropriate labeled mops or microfiber cleaning system. Cleans all buffer area totes and storage shelves by removing contents and using a germicidal detergent soaked lint free wipe, cleans the inside surfaces of the tote and then the entire exterior surfaces of the tote. Allows totes to dry. Prior to replacing contents into tote, wipes tote with sterile 70% IPA to remove disinfectant residue. Uses new wipe as needed. Cleans all buffer area carts by removing contents and using germicidal detergent soaked lint free wipe, cleans all carts starting with the top shelf and top of post, working down to wheels. Cleans the under side of shelves in a similar manner. Uses a new wipe for each cart. Allows to dry. Wipes carts with sterile 70% IPA wetted lint-free wipe to remove any disinfectant residue. Uses new wipe as needed. Cleans buffer area chairs, the interior and exterior of trash bins, and storage bins using disinfectant solution soaked lint free wipe. Documents all cleaning activities as to who performed such activities with date and time noted. * The person assessed is immediately informed of all unacceptable activities (i.e., spaces lacking a Check marks, N/A, or N/O) and shown and informed of specific corrections. Signature of Person Assessed Printed Name Date Signature of Qualified Evaluator Printed Name Date (Official J une 1, 2008) Copyright 2008 The United States Pharmacopeial Convention All Rights Reserved.